AMC & GM to Commission Implementing Regulation (EU) 2019-947 — Issue 1, Amendment 1

Annex I to ED Decision 2020/022/R ‘Acceptable Means of Compliance (AMC) and Guidance Material (GM) to Commission Implementing Regulation (EU) 2019/947 — Issue 1, Amendment 1’

Annex I to ED Decision 2019/021/R is amended as follows: The text of the amendment is arranged to show deleted text, new or amended text as shown below: (a) deleted text is marked with strikethrough; (b) new or amended text is highlighted in blue; (c) an ellipsis ‘(…)’ indicates that the remaining text is unchanged.

LIST OF ABBREVIATIONS AMC1 Article 11 Rules for conducting an operational risk assessment

SPECIFIC OPERATIONS RISK ASSESSMENT (SOURCE JARUS SORA V2.0) EDITION September 2019December 2020 […] 1.5 Roles and responsibilities […] (d) UAS manufacturer — For the purposes of the SORA, the UAS manufacturer is the party that designs and/or produces the UAS. The UAS manufacturer has unique design evidence (e.g. for the system performance, the system architecture, software/hardware development documentation, test/analysis documentation, etc.) that they may choose to make available to one or many UAS operator(s) or to the competent authority to help to substantiate the UAS operator’s safety case. Alternatively, a potential UAS manufacturer may utilise the SORA to target design objectives for specific or generalised operations. To obtain airworthiness approval(s), these design objectives could be complemented by the use of certification specifications (CS) or industry consensus standards if they are found to be acceptable by EASAthe competent authority. […] (f) Competent authority — The competent authority that is referred to throughout this AMC is the recognised national authority designated by the Member State in accordance with Article 17 of the UAS regulation to assess for approving the safety case of UAS operations and to issue the operational authorisation, according to in accordance with Article 12 of the UAS Regulation. The competent authority may accept an applicant’s SORA submission in whole or in part. Through the SORA process, the applicant may need to consult with the competent authority to ensure the consistent application or interpretation of individual steps. The competent authority must perform oversight of the UAS operator according toin accordance with paragraphs (i) and (j) of Article 18 of the UAS Regulation. According to Regulation (EU) 2018/1139 (the EASA ‘Basic Regulation’), EASA is the authority competent in the European Union to verify compliance of the UAS design and its components with the applicable rules, while the authority that is designated by the Member State is competent to verify compliance with the operational requirements and compliance of the personnel’s competency with those rules. The following elements are related to the UAS design: — OSOs #02, #04, #05, #06, #10, #12, #18, #19 (limited to criterion #3), #20, and #24; — M1 mitigation (tethered operations): criterion #1 and M2 mitigation: criterion #1;

— verification of the system to contain the UAS within the operational volume in accordance with Step #9 of the SORA process. When according to the SAIL or to the claimed mitigation means, the level of assurance of the above OSOs and/or mitigation means is ‘high’ (i.e. SAIL V and VI), a verification by EASA is required according to Article 40(1)(d) of Regulation (EU) 2019/945 . For the other OSOs and mitigation means, the competent authority defines which third party is able to verify compliance with them. If the level of robustness of the design-related OSOs and/or mitigation means is lower than ‘high’, the competent authority may still require a verification by EASA of the compliance of the UAS and/or its components with the design-related OSOs and/or mitigation means according to point Article 40(1)(d) of Regulation (EU) 2019/945. Similarly, also for UAS operators to which the competent authority granted a light UAS operator certificate (LUC), the terms of the approval may require to use a UAS that is verified by EASA when conducting operations for which the level of robustness of the design-related OSOs and/or mitigation means is lower than ‘high’. In those cases, EASA will verify that the achievement of the design integrity level is appropriate to the related SAIL and to the mitigation means, when those means are applicable, and will issue a type certificate (TC) (or a restricted type certificate (RTC)) to the UAS manufacturer, which will cover all design-related OSOs, the design-related mitigation means, and the enhanced containment verification in accordance with Step #9, if that verification is applicable. Alternatively, the competent authority that issues the operational authorisation may accept a declaration by the UAS operator, who is responsible for compliance of the UAS with the design-related OSOs.EASA may perform oversight of the UAS design and/or production organisation, and, when considered necessary, of the component design and/or production organisation, and may approve the design and/or the production of each. The competent authority also provides the operational approval to the UAS operator. […] 2. The SORA process […] 2.2 SORA process outline […]

Figure 3 — The SORA process

Note: If operations are conducted across different environments, some steps may need to be repeated for each particular environment.

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2.3 The ground risk process

2.3.1 Step #2 — Determination of the intrinsic UAS ground risk class (GRC)

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(c) The applicant needs to have defined the area at risk when conducting the operation (also called the ‘area of operation’) including:

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(d) Table 2 illustrates how to determine the intrinsic ground risk class (GRC). The intrinsic GRC is found at the intersection of the applicable operational scenario and the maximum UA characteristic dimension that drives the UAS lethal area. In case ofIf there is a mismatch between the maximum UAS characteristic dimension and the typical kinetic energy expected, the applicant should provide substantiation for the chosen column.

Table 1 — Determination of the intrinsic GRC

(e) The operational scenarios described an attempt to provide discrete categorisations of operations with increasing numbers of people at risk. In principle, it is possible to use either qualitative criteria (please refer to next point (f)) or quantitative criteria, or consider both criteria, to assess if an operation takes place over sparsely populated areas, populated areas, or assemblies of people.

(f) Reserved.Qualitative assessment: the volume to be used by the operator to classify the operation includes the operational volume and the ground risk buffer (as defined by a semantic model), which determine the intrinsic GRC. GM1 Article 2(3) ‘Definitions I DEFINITION OF ‘ASSEMBLIES OF PEOPLE’’ provides guidance on when an operation is classified as taking place over assemblies of people. An operation should be classified as taking place over a populated area if the volume that is used to determine the intrinsic GRC: — does not include assemblies of people, and — includes areas that are substantially used for residential, commercial or recreational purposes. […] (h) Controlled ground areas are a way to strategically mitigate the risk on ground (similar to flying in segregated airspace); the UAS operator should ensure, through appropriate procedures, thatassurance that there will be no uninvolved persons is in the area of operation, as defined in Section 2.3.1(c)is under the full responsibility of by the UAS operator.

[…] 2.3.2 Step #3 – Final GRC determination […] (h) In general, a quantitative approach to mitigation means allows to reduce the intrinsic GRC by 1 point if the mitigation means reduce the risk of the operation by a factor of approximately 10 (90 % reduction) compared to the risk that is assessed before the mitigation means are applied. Such quantitative criteria should be used to validate the risk reduction that is claimed when applying Annex B to AMC1 to Article 11. […] 2.5.2 Step #8 — Identification of the operational safety objectives (OSOs) (a) The last step of the SORA process is to use the SAIL to evaluate the defences within the operation in the form of OSOs, and to determine the associated level of robustness. Table 6 provides a qualitative methodology to make this determination. In this table, O is optional, L is recommended with low robustness, M is recommended with medium robustness, and H is recommended with high robustness. The various OSOs are grouped based on the threat they help to mitigate; hence, some OSOs may be repeated in the table. (b) Table 6 is a consolidated list of the common OSOs that historically have been used to ensure safe UAS operations. It represents the collected experience of many experts, and is therefore a solid starting point to determine the required safety objectives for a specific

operation. The competent authorities that issue the operational authorisation may define additional OSOs for a given SAIL and the associated level of robustness.

Table 6 — Recommended OSOs

2.5.3 Step #9 – Adjacent area/airspace considerations

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(c) The enhanced containment, which consists in the following three safety requirements, appliesy forto operations conducted:

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(2) Or where the operational volume is in a populated areaenvironments where:

(i) M1 mitigation has been applied to lower the GRC; or

(ii) operating in a controlled ground area.

ANNEX C TO AMC1 TO ARTICLE 11

STRATEGIC MITIGATION — COLLISION RISK ASSESSMENT […]

C.4 General air-SORA mitigation overview

SORA classification of mitigations The SORA classifies mitigations to suit the operational needs of a UAS in the ‘specific’ class. These mitigations are classified as: (a) strategic mitigations by the application of operational restrictions; (b) strategic mitigations by the application of common structures and rules; and (c) tactical mitigations.

Figure C.5 shows the alignment of the mitigation definitions between ICAO and the SORA.

Figure C.5 — SORA air conflict mitigation process

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ANNEX E TO APPENDIX A TO AMC1 TO ARTICLE 11

INTEGRITY AND ASSURANCE LEVELS FOR THE OPERATIONAL SAFETY OBJECTIVES (OSOs)

E.2 OSOs related to technical issues with the UAS

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OSO #02 — UAS manufactured by a competent and/or proven entity

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OSO #04 — UAS developed to authority recognised design standards

OSO #05 — UAS is designed considering system safety and reliability

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OSO #06 — C3 link characteristics (e.g. performance, spectrum use) are appropriate for the operation

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E.5 OSOs related to safe design

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E.7 OSOs related to Human Error

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OSO #19 — Safe recovery from human errors

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OSO #20 — A Human Factors evaluation has been performed and the HMI found appropriate for the mission

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E.9 Assurance level criteria for technical OSO

GM1 to AMC1 Article 11 Rules for conducting an operational risk assessment

GENERAL The operational risk assessment required by Article 11 of the UAS Regulation may be conducted using the methodology described in AMC1 to Article 11. This methodology is basically the specific operations risk assessment (SORA) developed by JARUS. Other methodologies may be used by the UAS operator as alternative means of compliance. Aspects other than safety, such as security, privacy, environmental protection, the use of the radio frequency (RF) spectrum, etc., should be assessed in accordance with the applicable requirements established by the Member State in which the operation is intended to take place, or by other EU regulations. For some UAS operations that are classified as being in the ‘specific’ category, alternatives to carrying out a full risk assessment are offered to UAS operators: (a) for UAS operations with lower intrinsic risks, a declaration may be submitted when the operations comply with the standard scenarios (STSs) listed in Appendix 1 to the UAS Regulation. Table 1 provides a summary of the STSs; and (b) for other UAS operations, a request for authorisation may be submitted based on the mitigations and provisions described in the predefined risk assessment (PDRA) when the UAS operation meets the operational characterisation described in AMC2 et seq. to Article 11 to the UAS Regulation. Table 2 below provides a summary of the PDRAs that have been published so far. While the STSs are described in a detailed way, the provisions and mitigations in the PDRAs are described in a rather generic way to provide flexibility to UAS operators and the competent authorities to establish more prescriptive limitations and provisions that are adapted to the particularities of the intended operations. Two types of PDRAs are provided: — those derived from an STS, which allow the UAS operator to conduct similar operations, but using, for example, UAS without the class label that is mandated by the STS (e.g. privately built UAS); and — more generic PDRAs. The codification of a PDRA includes the letter ‘G’ or ‘S’ (e.g. PDRA-G01 or PDRA-S01): — ‘G’ is used for generic PDRAs. — ‘S’ is used for PDRAs that are derived from an STS whose level of prescriptiveness is the same as of the corresponding STS. Therefore, those PDRAs, although they address UAS operations that are subject to operational authorisations (to allow the use of UAS without a class label), are expected to

provide an even more simplified authorisation process compared to other (non-STS-related) PDRAs. Ideally, for UAS operations that are performed based on those PDRAs, the competent authorities may implement expedited operational-authorisation processes. Those processes may be based on the review of the documentation that is submitted by the UAS operator to support the declaration of compliance with the PDRA provisions.

In accordance with Article 11 of the UAS Regulation, the applicant must collect and provide the relevant technical, operational and system information needed to assess the risk associated with the intended operation of the UAS, and the SORA (AMC1 to Article 11 of the UAS Regulation) provides a detailed framework for such data collection and presentation. The concept of operations (ConOps) description is the foundation for all other activities, and should be as accurate and detailed as possible. The ConOps should not only describe the operation, but also provide insight into the UAS operator’s operational safety culture. It should also include how and when to interact with the air navigation service provider (ANSP) when applicable.

PDRAs only address safety risks; consequently, additional limitations and provisions might need to be included after the consideration of other risks (e.g. security, privacy, etc.).

Table 1 — List of STSs published as ‘Appendix 1 for standard scenarios supporting a declaration’ to the Annex to the UAS Regulation

Table 2 — List of PDRAs published as AMC2-5 to Article 11 to the UAS Regulation

AMC2 Article 11 Rules for conducting an operational risk assessment

PREDEFINED RISK ASSESSMENT PRRA-G1PDRA-G01 Version 1.1 EDITION September 2019December 2020 (a) Scope This PDRA is the result of applying the methodology that is described in AMC1 to Article 11 of the UAS Regulation to UAS operations that are conductedperformed in the ‘specific’ category with the following main attributes: (1) with UA with maximum characteristic dimensions (e.g. wingspan, rotor diameter/area or maximum distance between rotors in case of multirotor) of up to 3 m and typical kinetic energyies of up to 34 kJ; (2) operated BVLOS of the remote pilot with visual air risk mitigation; (3) over sparsely populated areas; (4) less than 150 m (500 ft) above the overflown surface overflown (or any other altitude reference defined by the Member sState); and (5) in uncontrolled airspace. (b) PDRA characterisation and provisions The Ccharacterisation and provisions for this PDRA are summarised in Table PDRA-01.1Table PDRA-G01.1 below:.

PDRA characterisation and provisions

1. Operational characterisation (scope and limitations)

Level of human 1.1 No autonomous operations: the remote pilot should have the ability to maintain intervention control of the UA, except in case of a loss of the command and control (C2) link. 1.2 The remote pilot should only operate only one UA at a time. 1.3 The remote pilot should not operate from a moving vehicle. 1.4 The remote pilot should not hand over the control of the UA to another command unit.Handover between RPSs should not be performed. UA range limit 1.5 Launch/recovery: at VLOS distance from the remote pilot, if not operating from a safe prepared area. Note: ‘safe prepared area’ means a controlled ground area that is suitable for the safe launch/recovery of the UA. 1.6 In flight: 1.6.1 If no VOsAOs are employedused: the UA is not operated furtherat more than 1 km (or other distance defined by the competent authority) from the remote pilot. Note: The remote pilot’s workload should be adequate to allow him or herthe

remote pilot to continuously scan the airspace. 1.6.2 If VOsAOs are employedused: the range is not limited as long as the UA is not operated furtherat more than 1 km (unless a different distance is defined by the competent authority) from the VOsAO who is nearest to the UA.

Areas Ooverflown areas 1.7 UAS operations should be conducted over Ssparsely populated areas.

UA limitations 1.8 Maximum characteristic dimension (e.g. wingspan, rotor diameter/area or maximum distance between rotors in the case of a multirotor): 3 m 1.9 Typical kinetic energy (as defined in paragraph 2.3.1(k) of AMC1 to Article 11 of the UAS Regulation: up to 34 kJ

Flight height limit 1.10 The maximum height of the operational volume should not be greater than 150 m (500 ft) above the overflown surface (or any other altitude reference defined by the Member sState). Note: In addition to the vertical limit forof the operational volume, an air risk buffer is to be considered (see ‘aAir risk’ under point 3 of this table).

Airspace 1.11 The UA should be Ooperated: 1.11.1 in uncontrolled airspace (Class F or G) (corresponding to an air risk that can be classified as ARC-b); or 1.11.2 in a segregated area (corresponding to an air risk that can be classified as ARC-a); or 1.11.3 as otherwise established by the Member States in accordance with Article 15 (with an associated air risk that can be classified as not higher than ARC-b).

Visibility 1.12 The UA should be operated in an area where the minimum flight visibility is more than 5 km. Note: This flight visibility should be understood as the distance from whichthat an UAaircraft can be visually detected by the remote crew.

Others 1.13 The UA should not be used to drop material or carry dangerous goods, except for dropping items in connection with agricultural, horticultural or forestry activities in which the carriage of the items does not contravene any other applicable regulations.

2. Operational risk classification (according to the classification defined in AMC1 to Article 11 of the UAS Regulation)

Final GRC 3 Final ARC ARC-b SAIL II

3. Operational mitigations

Operational volume (see 3.1 To determine the operational volume, the UAS operator should consider the Figure 2 of AMC1 position-keeping capabilities of the UAS in 4D space (latitude, longitude, height, and Article 11PDRA-01.1) time). 3.2 In particular, the accuracy of the navigation solution, the flight technical error of the UAS, as well asand the flight path definition error (e.g. map error) and latencies should be considered and addressed in this determinationwhen determining the operational volume. 3.3 If the UA leaves the operational volume, emergency procedures should be activated immediately.The remote pilot should apply emergency procedures as soon as there is an indication that the UA may exceed the limits of the operational volume.

Ground risk 3.4 The UAS operator should establish a ground risk bufferA ground risk buffer should be established to protect third parties on the ground outside the operational volume. 3.4.1 The minimum criterion should be the use of the ‘1:1 rule’ (e.g. if the UA is planned to operate at a height of 150 m, the ground risk buffer should at least be 150 m). 3.5 The operational volume and the ground risk buffer should be all contained in a sparsely populated environmentarea. 3.6 The UAS operator should evaluate the area of operations typically by means of an on-site inspection or appraisal, and should be able to justify a lower density of people at risk.

Air risk 3.7 The UAS operator should establish an air risk buffer to protect third parties in the air outside the operational volume.An air risk buffer should be defined. 3.8 This air risk buffer should be contained in the ‘airspace class F or G’ airspace class (uncontrolled airspace) over sparsely populated areas and in UAS geographical zones defined by the MSs where the probability of encounter with manned aircraft and other airspace users is not low. 3.9 The operational volume should be outside any geographical zone corresponding to a flight restriction zone of a protected aerodrome or of any other type, as defined by the responsible authority, unless the UAS operator has been grantedis in receipt of thean appropriate permission. 3.10 Prior to the flight, the remote pilot should assess the proximity of the planned operation to manned aircraft activity should be assessed.

VOsObservers 3.11 If the UAS operator decides to employ one or more airspace observers (AOs), the remote pilot may operate the UA up to the distance that is specified in point 1.6.2. 3.1112 The remote pilotUAS operator should determineensure the correct placement and number of VOsAOs along the intended flight path. Prior to each flight, the UAS operator should checkverify that: 3.1112.1 the compliance between the visibility and planned range for VOsvisibility and the planned distance of the AO are within acceptable limits that are defined in the operations manual (OM); 3.1112.2 there are nopresence of potential terrain obstructions for each VOsAO; and 3.1112.3 there are no gaps between the zones that are covered by each of the VOsAOs.; 3.12.4communication with each AO is established and effective; and 3.12.5if means are used by the AOs to determine the position of the UA, those means are functioning and effective. 3.12 The VO(s) necessary to safely conduct the operation should be in place during flight operations. Note: Instead of an AO, Tthe remote pilot may perform the visual scan of the airspace, instead of a VO provided that the workload allows the remote pilotis adequate to perform his or hertheir duties as the remote pilot.

4. UAS Ooperator and UAS operations provisions

Operator 4.1 The UAS operator should: 4.1.1 have knowledge of the UAS being used; and 4.1.2 develop relevant procedures including at least the following as a minimum: operational procedures (e.g. checklists), maintenance, training, responsibilities, and duties. 4.2 The aforementioned aspects should be addressed in the ConOps (see Annex A to AMC1 to Article 11 of the UAS Regulation).

UAS operator and UAS 4.1 In addition to the responsibilities that are defined in point UAS.SPEC.050 of the operations Annex to the UAS Regulation and the provisions for UAS operators in previous points of this AMC, the UAS operator should: 4.31.1The UAS operator should develop an operations manual (OM) (for the template, refer to AMC1 UAS.SPEC.030(3)(e) and to the complementary information in GM1 UAS.SPEC.030(3)(e));. 4.61.2The UAS operator should develop an emergency response plan (ERP) (see point 7 of GM21 UAS.SPEC.030(3)(e)); 4.41.3validate Tthe operational procedures should be validated against standards that are recognised by the competent authority and/or in accordance with a means of compliance acceptable to that authority; 4.51.4ensure Tthe adequacy of the contingency and emergency procedures shouldand be proved them through any of the following: 4. 5.1(a) dedicated flight tests; or 4. 5.2(b) simulations, provided that the representativeness of the simulation means is proven for the intended purpose with positive results; or 4. 5.3(c) any other means acceptable to the competent authority. 4.101.5 The applicant should have a policy that defines how the remote crewpilot and all other personnel in charge of duties essential to the UAS operation can declare themselves fit to operate before conducting any operation. 4.7 The remote crew should be competent and be authorised by the UAS operator to carry out the intended operations. 4.8 A list of the remote crew members authorised to carry out UAS operations is established and kept up to date. 4.9 A record of all the relevant qualifications, experience and/or training completed by the remote crew is established and kept up to date.

UAS maintenance 4.112 The UAS maintenance instructions should bethat are defined by the UAS operator, documentedshould be included in the OM and should cover at least the UAS manufacturer’s instructions and requirements, when applicable. 4.12 The maintenance staff should be competent and should have received an authorisation from the UAS operator to carry out maintenance. 4.133 The maintenance staff should usefollow the UAS maintenance instructions whilewhen performing maintenance. 4.14 The maintenance instructions should be documented. 4.15 The maintenance conducted on the UAS should be recorded in a maintenance log system. 4.16 A list of the maintenance staff authorised to carry out maintenance should be established and kept up to date. 4.17 A record of all the relevant qualifications, experience and/or training completed by the maintenance staff should be established and kept up to date. 4.18 The maintenance log may be requested for inspection/audit by the approving authority or an authorised representative.

External services 4.194 The applicantUAS operator should ensure that the level of performance for any externally provided service that is necessary for the safety of the flight is adequate for the intended operation. The applicantUAS operator should declare that this adequate level of performance is adequately achieved. 4.205 The UAS operator should define and allocate the roles and responsibilities between the applicantUAS operator and the external service provider(s), if applicable. should be defined.

5. Provisions for the personnel in charge of duties essential to the UAS operation

As per Appendix A to AMC2 Article 11 The personnel in charge of duties essential to the

UAS operation

6. Technical provisions

General 6.1 The UAS should be equipped with Mmeans to monitor the critical parameters forof a safe flight should be available, in particular the: 6.1.1 UA position, height or altitude, ground speed or airspeed, attitude and trajectory; 6.1.2 UAS energy status (fuel, battery charge, etc.); and the 6.1.3 status of critical functions and systems; as a minimum, for services based on RF signals (e.g. C2 Link, GNSS, etc.), means should be provided to monitor the adequate performance and trigger an alert if the level becomes too low. 6.2 The UA should have the performance capability to descend safely from its operating altitude to a ‘safe altitude’ in less than a1 minute, or have a descent rate of at least 2.5 m/s (500 fpm).

Human-machine 6.3 The UAS information and control interfaces should be clearly and succinctly interface (HMI) presented and should not confuse, cause unreasonable fatigue, or contribute to causing any disturbance to the personnel in charge of duties essential to the UAS operation in such a way that this could adversely affect the safety of the operation. 6.4 If an electronic means is used to support VAOs in their role of maintaining awareness of the position of the unmanned aircraft, its HMI should: 6.4.1 be sufficiently easy to understand to allow the VAOs to determine the position of the UA during the operation; and 6.4.2 not degrade the VAOs’ ability to: 6.4.2.1 perform unaided visual scanning of the airspace where the UA is operating for any potential collision hazard; and 6.4.2.2 maintain effective communication with the remote pilot at all times. 6.5 The applicantUAS operator should conduct an UAS evaluation of the UAS that considersing and addressesing human factors to determine whether the HMI is appropriate for the operationmission.

C2 links and 6.6 The UAS should comply with the appropriateapplicable requirements for radio communication equipment and the use of the RF spectrum. 6.7 Protection mechanisms against interference should be used, especially if unlicensed bands (e.g. ISM) are used for the C2 Llink (mechanisms such as FHSS, technology or frequency de-confliction by procedure). 6.8 Communication between the remote pilot and the VAO(s) should allow the remote pilot to manoeuvre the UA with sufficient time to avoid any risk of collision with manned aircraft, in accordance with point UAS.SPEC.060(3)(b) of the UAS Regulation.

Tactical mitigation 6.9 The UAS design should be adequate to ensure that the time required between a command given by the remote pilot and the UA executing it does not exceed 5 seconds. 6.10 Where an electronic means is used to assist the remote pilot and/or VAOs in being aware of the UA position in relation to potential ‘airspace intruders’, the information is provided with a latency and an update rate for intruder data (e.g. position, speed, altitude, track) that support the decision criteria.

Containment 6.11 To ensure a safe recovery from a technical issue that involvesing the UAS or an external system supporting the operation, the UAS operator should ensure that: 6.11.1that no probable failure of the UAS or of any external system supporting the operation should lead to operation outside the operational volume; and. 6.11.2that it is reasonably expected that a fatality will not occur fromdue to any probable failure of the UAS, or of any external system supporting the operation. 6.12 The vertical extension of the operational volume should be 150 m above the surface (or any other altitude reference defined by the Member sState). Note: The term ‘probable’ shouldneeds to be understood in its qualitative

interpretation, i.e. ‘anticipated to occur one or more times during the entire

system/operational life of an item’.’

6.13 A design and installation appraisal should be made available and should minimally includecover at least: 6.13.1the design and installation features (independence, separation, and redundancy); and 6.13.2the particular risks (e.g. hail, ice, snow, electro-magneticelectromagnetic interference, etc.) relevant to the ConOps. 6.14 The following additional provisions should apply if the adjacent area includes an assembly of people or if the adjacent airspace is classified as ARC-d (in accordance with AMC1 to Article 11 of the UAS Regulation):. 6.14.1The UAS should be designed to standards that are considered adequate by the competent authority and/or in accordance with a means of compliance that is acceptable to that authority such that: 6.14.1.1 Tthe probability of the UA leaving the operational volume should -4 be less than 10-410 /FH; and. 6.14.1.2 Nno single failure of the UAS or of any external system supporting the operation should lead to operation outside the ground risk buffer. Note: The term ‘failure’ shouldneeds to be understood as an occurrence, thatwhich affects the operation of a component, part, or element in such a way that it can no longer function as intended. Errors may cause failures but are not considered to be failures. Some structural or mechanical failures may be excluded from thise criterion if it can be shown that these mechanical parts were designed according to aviation industry best practices. 6.14.26.3 SW and AEH whose development error(s) could directly lead to operations outside the ground risk buffer should be developed according to an industry standard or methodology that are recognised as adequate by the competent authority. Note 1: The proposed additional safety provisions cover both the integrity and assurance levels. Note 2: The proposed additional safety provisions do not imply a systematic need to develop the SW and AEH according to an industry standard or methodology that are recognised as adequate by the competent authority. For instance, if the UA design includes an independent engine shutdown function whichthat systematically prevents the UA from exiting the ground risk buffer due to single failures or a SW/AEH error of the flight controls, the intent of the provisions of point 6.14.16.16.2 and 6.16.3 above could be considered to be met. 6.15 Compliance with the provisions of points 6.14.116.1 and 6.14.2 above should be substantiated by analysis and/or test data with supporting evidence.

Table PDRA-G01.21 — Main limitations and provisions for PDRA-G01

Appendix A to AMC2 Article 11: The personnel in charge of duties essential to the UAS operation

[…] A.2. VOsAOs A.2.1 The VOsAOs’ main responsibilities should be to: A.2.1.1 perform unaidedmaintain a thorough visual scanning of the airspace that is surrounding the UA, to identify any risk of collision with manned aircraftwhere the UA is operating for any potential hazard in the air; […]

AMC3 Article 11 Rules for conducting an operational risk assessment

PREDEFINED RISK ASSESSMENT PDRA-G02 Version 1.0 EDITION December 2020 (a) Scope This PDRA is the result of applying the methodology that is described in AMC1 Article 11 of the UAS Regulation to UAS operations that are conducted in the ‘specific’ category: (1) with UA with maximum characteristic dimensions (e.g. wingspan, rotor diameter/area or maximum distance between rotors in case of multirotor) of up to 3 m and typical kinetic energy of up to 34 kJ; (2) BVLOS of the remote pilot; (3) over sparsely populated areas;

(4) in airspace that is reserved for the operation: either a danger area or a restricted area appropriate for UAS operations. (b) PDRA characterisation and provisions The characterisation and provisions for this PDRA are summarised in Error! Reference source not found. PDRA-G02.1 below:

PDRA characterisation and provisions

1. Operational characterisation (scope and limitations)

Level of human 1.1 No autonomous operations: the remote pilot should have the ability to maintain intervention control of the UA, except in case of loss of the command and control (C2) link. 1.2 The remote pilot should operate only one UA at a time. UA range limit 1.3 Launch/recovery: at VLOS distance from the remote pilot, if not operating from a safe prepared area. Note: ‘safe prepared area’ means a controlled ground area that is suitable for the safe launch/recovery of the UA. 1.4 In flight: The range limit should be within the C2 link coverage that ensures the safe conduct of the flight. Areas overflown 1.5 UAS operations should be conducted over sparsely populated areas. UA limitations 1.6 Maximum characteristic dimension (e.g. wingspan, rotor diameter/area or maximum distance between rotors in case of a multirotor): 3 m 1.7 Typical kinetic energy (as defined in paragraph 2.3.1(k) of AMC1 Article 11 of the UAS Regulation): up to 34 kJ Flight height limit 1.8 The maximum height of the operation volume is limited by the size of the reserved airspace. Note: In addition to the vertical limit of the operational volume, an air risk buffer is to be considered (see ‘Air risk’ under point 3 of this table). Airspace 1.9 Operations should only be conducted in airspace that is reserved for the operation (corresponding to an air risk that can be classified as ARC-a). Note: ‘Reserved airspace’ means here either a danger area or a restricted area that is designated for UAS operations. Visibility 1.10 If take-off and landing are conducted in VLOS of the remote pilot, visibility should be sufficient to ensure that no people are in danger during the take-off/landing phase. The remote pilot should abort the take-off or landing in case people on the ground are in danger. Others 1.11 The UA should not be used to drop material or carry dangerous goods, except for dropping items in connection with agricultural, horticultural or forestry activities in

which the carriage of the items does not contravene any other applicable regulations.

2. Operational risk classification (according to the classification defined in AMC1 Article 11 of the UAS Regulation)

Final GRC 3 Final ARC ARC-a SAIL II

3. Operational mitigations

Operational volume 3.1 To determine the operational volume, the UAS operator should consider the (see Figure 2 of position-keeping capabilities of the UAS in 4D space (latitude, longitude, height, and AMC1 Article 11) time). 3.2 In particular, the accuracy of the navigation solution, the flight technical error of the UAS, as well as the flight path definition error (e.g. map error) and latencies should be considered and addressed when determining the operational volume. 3.3 The remote pilot should apply the emergency procedures as soon as there is an indication that the UA may exceed the limits of the operational volume.

Ground risk 3.4 The UAS operator should establish a ground risk buffer to protect third parties on the ground outside the operational volume. 3.4.1 The minimum criterion should be the use of the ‘1:1 rule’ (e.g. if the UA is planned to operate at a height of 150 m, the ground risk buffer should at least be 150 m). 3.5 The operational volume and the ground risk buffer should be all contained in a sparsely populated area. 3.6 The UAS operator should evaluate the area of operations typically by means of an on-site inspection or appraisal, and should be able to justify a lower density of people at risk.

Air risk 3.7 The operational volume should be entirely contained in the reserved airspace. 3.8 The operational volume should be outside any geographical zone corresponding to a flight restriction zone, as defined by the responsible authority, unless the UAS operator has been granted an appropriate permission.

Observers N/A

4. UAS operator and UAS operations provisions

UAS operator and UAS 4.1 In addition to the responsibilities that are defined in point UAS.SPEC.050 of the operations Annex to the UAS Regulation and the provisions for UAS operators in previous points of this AMC, the UAS operator should: 4.1.1 develop an operations manual (OM) (for the template, refer to AMC1 UAS.SPEC.030(3)(e) and to the complementary information in GM1 UAS.SPEC.030(3)(e)); 4.1.2 develop an emergency response plan (ERP) (see point 7 of GM2 UAS.SPEC.030(3)(e)); 4.1.3 validate the operational procedures against standards that are recognised by the competent authority and/or in accordance with a means of compliance acceptable to that authority; 4.1.4 ensure the adequacy of the contingency and emergency procedures and prove it through any of the following: (a) dedicated flight tests; or (b) simulations, provided that the representativeness of the simulation means is proven for the intended purpose with positive results; or (c) any other means acceptable to the competent authority; 4.1.5 have a policy that defines how the remote pilot and all other personnel in charge of duties essential to the UAS operation can declare themselves fit to operate before conducting any operation. 4.1.6 as part of the procedures that are contained in the OM (point 4.1.1 above), include the description of the following: (a) The method and means of communication with the authority or entity responsible for the management of the airspace during the entire period of the reserved or restricted airspace being active, as mandated by the authorisation. Note: The communication method should be published in the notice to airmen (NOTAM), which activates the reserved airspace to also allow coordination with manned aircraft. (b) The member(s) of personnel in charge of duties essential to the UAS operation, who are responsible for establishing that communication.

UAS maintenance 4.2 The UAS maintenance instructions that are defined by the UAS operator should be included in the OM and should cover at least the UAS manufacturer’s instructions and requirements, when applicable. 4.3 The maintenance staff should follow the UAS maintenance instructions when performing maintenance.

External services 4.4 The UAS operator should ensure that the level of performance for any externally provided service that is necessary for the safety of the flight is adequate for the intended operation. The UAS operator should declare that this level of performance is adequately achieved. 4.5 The UAS operator should define and allocate the roles and responsibilities between the UAS operator and the external service provider(s), if applicable.

5. Provisions for the personnel in charge of duties essential to the UAS operation

As per Appendix A to AMC2 Article 11 The personnel in charge of duties essential to the

UAS operation

6. Technical provisions

General 6.1 The UAS should be equipped with means to monitor the critical parameters of a safe flight, in particular the: 6.1.1 UA position, height or altitude, ground speed or airspeed, attitude, and trajectory; 6.1.2 UAS energy status (fuel, battery charge, etc.); and 6.1.3 status of critical functions and systems; as a minimum, for services based on RF signals (e.g. C2 link, GNSS, etc.), means should be provided to monitor the adequate performance and trigger an alert if the performance level becomes too low.

Human–machine 6.3 The UAS information and control interfaces should be clearly and succinctly interface (HMI) presented and should not confuse, cause unreasonable fatigue, or contribute to causing any disturbance to the personnel in charge of duties essential to the UAS operation in such a way that could adversely affect the safety of the operation. 6.4 The UAS operator should conduct a UAS evaluation that considers and addresses human factors to determine whether the HMI is appropriate for the operation.

C2 links and 6.5 The UAS should comply with the applicable requirements for radio equipment and communication use of the RF spectrum. 6.6 Protection mechanisms against interference should be used, especially if unlicensed bands (e.g. ISM) are used for the C2 link (mechanisms such as FHSS, technology or frequency deconfliction by procedure). 6.7 The UAS operator should ensure that reliable and continuous means of two-way communication for the purpose that is indicated in point 4.1.6(a) above are available.

Tactical mitigation N/A

Containment 6.8 To ensure a safe recovery from a technical issue that involves the UAS or an external system supporting the operation, the UAS operator should ensure that: 6.8.1 no probable failure of the UAS or of any external system supporting the operation should lead to operation outside the operational volume; and

6.8.2 that it is reasonably expected that a fatality will not occur due to any probable failure of the UAS or of any external system supporting the operation. Note: The term ‘probable’ should be understood in its qualitative interpretation, i.e. ‘anticipated to occur one or more times during the entire system/operational life of an item’. 6.9 A design and installation appraisal should be made available and should cover at least: 6.9.1 the design and installation features (independence, separation, and redundancy); and 6.9.2 the particular risks (e.g. hail, ice, snow, electromagnetic interference, etc.) relevant to the ConOps. 6.10 The following additional provisions should apply if the adjacent area includes an assembly of people or if the adjacent airspace is classified as ARC-d (in accordance with AMC1 Article 11 of the UAS Regulation). 6.10.1The UAS should be designed to standards that are considered adequate by the competent authority and/or in accordance with a means of compliance that is acceptable to that authority such that: 6.10.1.1 the probability of the UA leaving the operational volume should –4 be less than 10 /FH; and 6.10.1.2 no single failure of the UAS or of any external system supporting the operation should lead to operation outside the ground risk buffer. Note: The term ‘failure’ should be understood as an occurrence that affects the operation of a component, part, or element in such a way that it can no longer function as intended. Errors may cause failures but are not considered to be failures. Some structural or mechanical failures may be excluded from the criterion if it can be shown that these mechanical parts were designed according to aviation industry best practices. 6.10.2SW and AEH whose development error(s) could directly lead to operations outside the ground risk buffer should be developed according to an industry standard or methodology that are recognised as adequate by the competent authority. Note 1: The proposed additional safety provisions cover both the integrity and assurance levels. Note 2: The proposed additional safety provisions do not imply a systematic need to develop the SW and AEH according to an industry standard or methodology that are recognised as adequate by the competent authority. For instance, if the UA design includes an independent engine shutdown function that systematically prevents the UA from exiting the ground risk buffer due to single failures or an SW/AEH error of the flight controls, the intent of the provisions of point 6.10.1 above could be considered to be met. 6.11 Compliance with the provisions of points 6.10.1 and 6.10.2 above should be substantiated by analysis and/or test data with supporting evidence.

Table PDRA-G02.1 — Main limitations and provisions for PDRA-G02

AMC4 Article 11 Rules for conducting an operational risk assessment

PREDEFINED RISK ASSESSMENT PDRA-S01 Version 1.0 EDITION December 2020 (a) Scope This PDRA addresses the same type of operations that are covered by the standard scenario STS-01 (Appendix 1 to the Annex to the UAS Regulation); however, it provides the UAS operator with the flexibility to use UAS that do not need to be marked as Class C5. This PDRA addresses UAS operations that are conducted: (1) with UA with maximum characteristic dimensions (e.g. wingspan, rotor diameter/area or maximum distance between rotors in case of multirotor) of up to 3 m and MTOM of up to 25 kg; (2) in VLOS of the remote pilot; (3) over a controlled ground area that might be located in a populated area; (4) not higher than 120 m above the surface overflown (except when close to obstacles); and (5) in controlled or uncontrolled airspace, provided that there is a low probability of encountering manned aircraft. (b) PDRA characterisation and provisions The characterisation and provisions for this PDRA are summarised in Table PDRA-S01.1 below:

PDRA characterisation and provisions

1. Operational characterisation (scope and limitations)

Level of human 1.1 No autonomous operations: the remote pilot should have the ability to maintain intervention control of the UA, except in case of loss of the command and control (C2) link. 1.2 The remote pilot should operate only one UA at a time. 1.3 The remote pilot should not operate from a moving vehicle. 1.4 The remote pilot should not hand over the control of the UA to another command unit. UA range limit 1.5 VLOS distance from the remote pilot at all times. 1.6 UAS operations should be conducted over a controlled ground area. 1.7 For the operation of a tethered UA, the area should have a radius equal to the tether Areas overflown length plus 5 m and should be centred on the point of the surface of the Earth where the tether is fixed. UA limitations 1.8 The UA should have an MTOM of less than 25 kg, including payload.

1.9 The UA should have a maximum characteristic dimension (e.g. wingspan, rotor diameter/area or maximum distance between rotors in case of multirotor) of less than 3 m.

Flight height limit 1.10 The remote pilot should maintain the UA within 120 m from the closest point of the surface of the Earth. The measurement of the distances should be adapted according to the geographical characteristics of the terrain, such as plains, hills, and mountains. 1.11 When flying a UA within a horizontal distance of 50 m from an artificial obstacle that is taller than 105 m, the maximum height of the UAS operation may be increased up to 15 m above the height of the obstacle, at the request of the entity responsible for the obstacle. 1.12 The maximum height of the operational volume should not exceed by 30 m the maximum height that is allowed by points 1.10 and 1.11 above.

Airspace 1.13 The UA should be operated: 1.13.1 in uncontrolled airspace (Class F or G), unless different limitations are provided for by the Member States for their UAS geographical zones in areas where the probability of encountering manned aircraft is not low; or 1.13.2 in controlled airspace after coordination and flight authorisation in accordance with the published procedures for the area of operation, to ensure a low probability of encountering manned aircraft. Note: An airspace with an air risk that is classified as not higher than ARC-b can be considered having a low probability of encountering manned aircraft.

Visibility 1.14 The flight visibility should allow the remote pilot to conduct the entire flight in VLOS.

Others 1.15 The UA should not be used to carry dangerous goods, except for dropping items in connection with agricultural, horticultural or forestry activities in which the carriage of the items does not contravene any other applicable regulations.

2. Operational risk classification (according to the classification defined in AMC1 Article 11 of the UAS Regulation)

Final GRC 3 Final ARC ARC-b SAIL II

3. Operational mitigations

Operational volume 3.1 The UAS operator should define the operational volume for the intended operation, (see Figure 2 of including: AMC1 Article 11) 3.1.1 the flight geography; and 3.1.2 the contingency volume, with its external limit(s) at least 10 m beyond the limit(s) of the flight geography if the operation is conducted with untethered UA. 3.2 To determine the operational volume, the UAS operator should consider the position-keeping capabilities of the UAS in 4D space (latitude, longitude, height, and time). 3.3 In particular, the accuracy of the navigation solution, the flight technical error of the UAS, as well as the flight path definition error (e.g. map error) and latencies should be considered and addressed when determining the operational volume. 3.4 The remote pilot should apply emergency procedures as soon as there is an indication that the UA may exceed the limits of the operational volume, as per point 5.1.4(d) below.

Ground risk 3.5 The UAS operator should establish a ground risk buffer to protect third parties on the ground outside the operational volume. 3.6 For the operation of untethered UA, the ground risk buffer should cover a distance beyond the external limit(s) of the contingency area. That distance should be at least as defined below:

Maximum Minimum distance to be covered by the ground height above risk buffer for untethered UA ground with an MTOM of up to with an MTOM of more 10 kg than 10 kg 30 m 10 m 20 m 60 m 15 m 30 m 90 m 20 m 45 m 120 m 25 m 60 m

3.7 For the operation of tethered UA, the ground risk buffer is considered in point 1.7 above.

Air risk 3.8 The operational volume should be outside any geographical zone corresponding to a flight restriction zone of a protected aerodrome or of any other type, as defined by the responsible authority, unless the UAS operator has been granted an appropriate permission. 3.9 Prior to the flight, the UAS operator should assess the proximity of the planned operation to manned aircraft activity.

Observers Airspace observers (AOs): N/A. UA observers: refer to point 5.1.4(b) below.

4. UAS operator and UAS operations provisions

UAS operator and UAS 4.1 In addition to the responsibilities that are defined in point UAS.SPEC.050 of the operations Annex to the UAS Regulation, and the provisions for UAS operators in previous points of this AMC, the UAS operator should: 4.1.1 develop an operations manual (OM) (for the template, refer to AMC1 UAS.SPEC.030(3)(e) and to the complementary information in GM1 UAS.SPEC.030(3)(e)); 4.1.2 define the operational volume and ground risk buffer for the intended operation, as per points 3.1 to 3.6 above, and include them in the OM; 4.1.3 ensure the adequacy of the contingency and emergency procedures and prove it through any of the following: (a) dedicated flight tests; or (b) simulations, provided that the representativeness of the simulation means is proven for the intended purpose with positive results; or (c) any other means acceptable to the competent authority; 4.1.4 develop an effective emergency response plan (ERP) that is suitable for the intended operation (see GM1 UAS.SPEC.030(3)(e)); 4.1.5 upload updated information into the geo-awareness function, if such system is installed on the UAS, when required by the UAS geographical zone for the intended location of the operation; 4.1.6 ensure that before starting the operation, the controlled ground area is in place, effective, and compliant with the minimum distance that is defined in points 3.1 and 3.5 above and, when required, coordination with the appropriate authorities has been established; 4.1.7 ensure that before starting the operation, all persons that are present in the controlled ground area: (a) have been informed of the risks of the operation; (b) have been briefed on or trained in, as appropriate, the safety precautions and measures that the UAS operator has established for their protection; and (c) have explicitly agreed to participate in the operation; and 4.1.8 ensure that the UAS that is used in the intended operation complies with the technical provisions of point 6 below. 4.2 A UAS operation under this PDRA should be conducted: 4.2.1 keeping the UA in VLOS of the remote pilot at all times; 4.2.2 in accordance with the OM that is referred to in point 4.1.1 above; 4.2.3 over a controlled ground area that comprises the area of the operational volume that is indicated in point 3.1 above and the ground risk buffer that is indicated in point 3.5 above, both projected on the surface of the Earth; 4.2.4 at a ground speed of less than 5 m/s in case of untethered UA; 4.2.5 by a remote pilot that complies with point 5.1 below; and 4.2.6 with a UA that complies with point 6 below.

UAS maintenance 4.3 The UAS maintenance instructions that are defined by the UAS operator should be included in the OM and should cover at least the UAS manufacturer’s instructions and requirements, when applicable. 4.4 The maintenance staff should follow the UAS maintenance instructions when performing maintenance.

External services 4.5 The UAS operator should ensure that the level of performance for any externally provided service that is necessary for the safety of the flight is adequate for the intended operation. The UAS operator should declare that this level of performance is adequately achieved. 4.6 The UAS operator should define and allocate the roles and responsibilities between the UAS operator and the external service provider(s), if applicable.

5. Provisions for the personnel in charge of duties essential to the UAS operation

Remote pilot 5.1 In addition to complying with the requirements of point UAS.SPEC.060 of the Annex to the UAS Regulation and with the provisions for remote pilots in previous points of this AMC, a remote pilot who is engaged in operations under this PDRA should: 5.1.1 hold a certificate of remote-pilot theoretical knowledge, in accordance with Attachment A to Chapter I of Appendix 1 to the Annex to the UAS Regulation, which is issued by the competent authority or by an entity that is designated by the competent authority of a Member State; 5.1.2 hold an accreditation of completion of a practical-skill training course for this PDRA, in accordance with Attachment A to Chapter I of Appendix 1 to the Annex to the UAS Regulation, which is issued by: (a) an entity that has declared compliance with the requirements of Appendix 3 to the Annex to the UAS Regulation and is recognised by the competent authority of a Member State; or (b) a UAS operator that has declared to the competent authority of the Member State of registration compliance with this PDRA and with the requirements of Appendix 3 to the Annex to the UAS Regulation; 5.1.3 before starting the UAS operation, verify that the means to terminate the flight of the UA as well as the remote identification system are operational; and 5.1.4 during the flight: (a) keep the UA in VLOS and maintain a thorough visual scan of the airspace that is surrounding the UA to avoid any risk of collision with manned aircraft; the remote pilot should discontinue the flight if the operation poses a risk to other aircraft, people, animals, environment or property; (b) for the purpose of point (a) above, be possibly assisted by a UA observer; clear and effective communication should be established between the remote pilot and the UA observer; (c) use the contingency procedures that are defined by the UAS operator for abnormal situations, including situations where the remote pilot has an indication that the UA may exceed the limits of the flight geography; and (d) use the emergency procedures that are defined by the UAS operator for emergencies, including triggering the means to terminate the flight when the remote pilot has an indication that the UA may exceed the limits of the operational volume; the means to terminate the flight should be triggered at least 10 m before the UA reaches the limits of the operational volume.

6. Technical provisions

UAS 6.1 A UAS that is to be used in operations under this PDRA should comply with the requirements of Part 16 of the Annex to Regulation (EU) 2019/945 , except that the UAS does not need to: 6.1.1 bear a Class C3 UAS or Class C5 UAS identification on itself; 6.1.2 be exclusively powered by electricity, if the UAS operator ensures that the environmental impact that is caused by the use of non-electric UAS is minimised; 6.1.3 include a notice that is published by EASA and provides the applicable limitations and obligations, as required by the UAS Regulation; and 6.1.4 include the manufacturer’s instructions for the UAS if it is privately built; however, information on its operation and maintenance, as well as on the training of the remote pilot, should be included in the OM. Note 1: The UAS can comply with point (9) of Part 4 of the Annex to Regulation (EU) 2019/945 by using an add-on that complies with Part 6 of the Annex to said Regulation. Note 2: If the UA does not have a physical serial number that is compliant with standard ANSI/CTA-2063-A ‘Small Unmanned Aerial Systems Serial Numbers’ and/or does not have an integrated system of direct remote identification, it can comply with point (9) of Part 4 of the Annex to Regulation (EU) 2019/945 by using an add-on that complies with Part 6 of the Annex to said Regulation. Note 3: If the UAS is privately built, there may be no identification on the UA of its MTOM. In that case, the operator should ensure that the MTOM of the UA, in the configuration of the UA before take-off, does not exceed 25 kg.

Table PDRA-S01.1 — Main limitations and provisions for PDRA-S01

AMC5 Article 11 Rules for conducting an operational risk assessment

PREDEFINED RISK ASSESSMENT PDRA-S02 Version 1.0 EDITION December 2020 (a) Scope This PDRA addresses the same type of operations that are covered by the standard scenario STS-02 (Appendix 1 to the Annex to the UAS Regulation); however, it provides the UAS operator with the flexibility to use UAS that do not need to be marked as Class C6. This PDRA addresses UAS operations that are conducted: (1) with UA with maximum characteristic dimensions (e.g. wingspan, rotor diameter/area or maximum distance between rotors in case of multirotor) of up to 3 m and MTOM of up to 25 kg; (2) at a distance of up to 2 km from the remote pilot if airspace observers (AOs) are employed; otherwise at a distance of up to 1 km; (3) over a controlled ground area that is entirely located in a sparsely populated area; (4) not higher than 120 m above the surface overflown (except when close to obstacles); and (5) in controlled or uncontrolled airspace, provided that there is a low probability of encountering manned aircraft. (b) PDRA characterisation and provisions The characterisation and provisions for this PDRA are summarised in Table PDRA-S02.1 below:

PDRA characterisation and provisions

1. Operational characterisation (scope and limitations)

Level of human 1.1 No autonomous operations: the remote pilot should maintain control of the UA, intervention except in case of loss of the command and control (C2) link. 1.2 The remote pilot should operate only one UA at a time. 1.3 The remote pilot should not operate from a moving vehicle. 1.4 The remote pilot should not hand over the control of the UA to another command unit. UA range limit 1.5 UAS operations should be conducted: 1.5.1 keeping the UA in sight of the remote pilot during the launch and recovery of the UA, unless the recovery of the UA is the result of an emergency flight termination; 1.5.2 if no airspace observer (AO) is employed in the operation, with the UA no further than 1 km from the remote pilot; and

1.5.3 if one or more AOs are employed in the operation, with the UA no further than 2 km from the remote pilot.

Areas overflown 1.6 UAS operations should be conducted over a controlled ground area.

UA limitations 1.7 The UA should have an MTOM of less than 25 kg, including payload. 1.8 The UA should have maximum characteristic dimensions (e.g. wingspan, rotor diameter/area or maximum distance between rotors in case of multirotor) of less than 3 m. 1.9 The UA should have a maximum ground speed in level flight of not more than 50 m/s.

Flight height limit 1.10 The remote pilot should maintain the UA within 120 m from the closest point of the surface of the Earth. The measurement of the distances should be adapted according to the geographical characteristics of the terrain, such as plains, hills, and mountains. 1.11 When flying a UA within a horizontal distance of 50 m from an artificial obstacle that is taller than 105 m, the maximum height of the UAS operation may be increased up to 15 m above the height of the obstacle at the request of the entity responsible for the obstacle. 1.12 The maximum height of the operational volume should not exceed by 30 m the maximum height that is allowed by points 1.10 and 1.11 above.

Airspace 1.13 The UA should be operated: 1.13.1 in uncontrolled airspace (Class F or G), unless different limitations are provided for by the Member States for their UAS geographical zones in areas where the probability of encountering manned aircraft is not low; or 1.13.2 in controlled airspace after coordination and flight authorisation in accordance with the published procedures for the area of operation, to ensure a low probability of encountering manned aircraft. Note: An airspace with an air risk that is classified as not higher than ARC-b can be considered having a low probability of encountering manned aircraft.

Visibility 1.14 The UA operation should be conducted in an area where the flight visibility is more than 5 km.

Others 1.15 The UA should not be used to carry dangerous goods, except for dropping items in connection with agricultural, horticultural or forestry activities in which the carriage of the items does not contravene any other applicable regulations.

2. Operational risk classification (according to the classification defined in AMC1 Article 11 of the UAS Regulation)

Final GRC 3 Final ARC ARC-b SAIL II

3. Operational mitigations

Operational volume (see 3.1 The UAS operator should define the operational volume for the intended operation, Figure PDRA-G01.1 of including the flight geography and the contingency volume. AMC2 Article 11) 3.2 To determine the operational volume, the UAS operator should consider the position-keeping capabilities of the UAS in 4D space (latitude, longitude, height, and time). 3.3 In particular, the accuracy of the navigation solution, the flight technical error of the UAS, as well as the flight path definition error (e.g. map error) and latencies should be considered and addressed when determining the operational volume. 3.4 The remote pilot should apply emergency procedures as soon as there is an indication that the UA may exceed the limits of the operational volume, as per point 5.1.4(h) below.

Ground risk 3.5 The UAS operator should establish a ground risk buffer to protect third parties on the ground outside the operational volume. 3.6 The ground risk buffer should cover a distance that is at least equal to the distance specified by the UAS manufacturer’s instructions, considering the operational conditions within the limitations specified by the UAS manufacturer.

Air risk 3.7 The operational volume should be outside any geographical zone corresponding to a flight restriction zone of a protected aerodrome or of any other type, as defined by the responsible authority, unless the UAS operator has been granted an appropriate permission. 3.8 Prior to the flight, the UAS operator should assess the proximity of the planned operation to manned aircraft activity.

Observers 3.9 If the UAS operator decides to employ one or more airspace observers (AOs), the UA may be operated at a distance from the remote pilot greater than that referred to in point 1.5.2 above. 3.10 In relation to AOs, the UAS operator should comply with the provisions of point 4.1.8 below. 3.11 AOs should comply with the provisions of point 5.2 below.

4. UAS operator and UAS operations provisions

UAS operator and UAS 4.1 In addition to the responsibilities that are defined in point UAS.SPEC.050 of the operations Annex to the UAS Regulation, the UAS operator should: 4.1.1 develop an operations manual (OM) (for the template, refer to AMC1 UAS.SPEC.030(3)(e) and to the complementary information in GM1 UAS.SPEC.030(3)(e)); 4.1.2 define the operational volume and ground risk buffer for the intended operation, as per points 3.1 to 3.6 above, and include them in the OM; 4.1.3 ensure the adequacy of the contingency and emergency procedures and prove it through any of the following: (a) dedicated flight tests; or (b) simulations, provided that the representativeness of the simulation means is proven for the intended purpose with positive results; or (c) any other means acceptable to the competent authority; 4.1.4 develop an effective emergency response plan (ERP) that is suitable for the intended operation (see GM1 UAS.SPEC.030(3)(e)); 4.1.5 upload updated information into the geo-awareness function, if such system is installed on the UAS, when required by the UAS geographical zone for the intended location of the operation; 4.1.6 ensure that before starting the operation, the controlled ground area is in place, effective, and compliant with the minimum distance that is defined in points 3.1 to 3.6 above as well as that, when required, coordination with the appropriate authorities has been established; 4.1.7 ensure that before starting the operation, all persons that are present in the controlled ground area: (a) have been informed of the risks of the operation; (b) have been briefed on or trained in, as appropriate, the safety precautions and measures that the UAS operator established for their protection; and (c) have explicitly agreed to participate in the operation; and 4.1.8 before starting the operation, and if airspace observers (AOs) are employed: (a) ensure the correct placement and number of AOs along the intended flight path; (b) verify that: (i) visibility and the planned distance of the AO are within acceptable limits as defined in the OM; (ii) there are no potential terrain obstructions for each AO; (iii) there are no gaps between the zones that are covered by each of the AOs;

(iv) the communication with each AO is established and effective; and (v) if means are used by the AOs to determine the position of the UA, those means are functioning and effective; and (c) ensure that the AOs have been briefed on the planned flight path of the UA and on the associated timing; and 4.1.9 ensure that the UAS that is used in the intended operation complies with the technical provisions of point 6 below. 4.2 A UAS operation under this PDRA should be conducted: 4.2.1 keeping the UA in sight of the remote pilot during the launch and recovery of the UA, unless the recovery of the UA is the result of an emergency flight termination; 4.2.2 in accordance with the OM that is referred to in point 4.1.1 above; 4.2.3 over a controlled ground area that comprises the area of the operational volume that is indicated in point 3.1 above and the ground risk buffer that is indicated in point 3.5 above, both projected on the surface of the Earth; 4.2.4 by a remote pilot that complies with point 5.1 below; and 4.2.5 with a UA that complies with point 6 below and is operated with: (a) an active system to prevent the UA from exceeding the limits of the flight geography; and (b) an active and updated system of direct remote identification. 4.3 If no AO is employed in the operation, the operation should be conducted with the UA flying no further from the remote pilot than the distance that is indicated in point 1.2.2 above and following a preprogrammed trajectory when the UA is not in VLOS of the remote pilot. 4.4 If one or more AOs are employed in the operation, the following conditions should be complied with: 4.4.1 the AO(s) should be positioned so as to adequately cover the operational volume and the surrounding airspace, having the minimum flight visibility that is indicated in point 1.10 above; 4.4.2 the UA should be operated no further than 1 km from the AO who is nearest to the UA; 4.4.3 the distance between any AO and the remote pilot should not be more than 1 km; and 4.4.4 robust and effective means are available for communication between the remote pilot and the AO(s).

UAS maintenance 4.5 The UAS maintenance instructions that are defined by the UAS operator should be included in the OM and should cover at least the UAS manufacturer’s instructions and requirements, when applicable. 4.6 The maintenance staff should follow the UAS maintenance instructions when performing maintenance.

External services 4.7 The UAS operator should ensure that the level of performance for any externally provided service that is necessary for the safety of the flight is adequate for the intended operation. The UAS operator should declare that this level of performance is adequately achieved. 4.8 The UAS operator should define and allocate the roles and responsibilities between the UAS operator and the external service provider(s), if applicable.

5. Provisions for the personnel in charge of duties essential to the UAS operation

Remote pilot 5.1 In addition to complying with the requirements of point UAS.SPEC.060 of the Annex to the UAS Regulation and with the provisions for remote pilots in previous points of this AMC, a remote pilot who is engaged in operations under this PDRA should: 5.1.1 hold a certificate of remote-pilot theoretical knowledge, in accordance with Attachment A to Chapter II of Appendix 1 to the Annex to the UAS Regulation, which is issued by the competent authority or by an entity that is designated by the competent authority of a Member State; 5.1.2 hold an accreditation of completion of a practical-skill training course for this PDRA, in accordance with Attachment A to Chapter II of Appendix 1 to the Annex to the UAS Regulation, which is issued by: (a) an entity that has declared compliance with the requirements of Appendix 3 to the Annex to the UAS Regulation and is recognised by the competent authority of a Member State; or (b) a UAS operator that has declared to the competent authority of the Member State of registration compliance with this PDRA and with the requirements of Appendix 3 to the Annex to the UAS Regulation; 5.1.3 before starting the UAS operation: (a) set the programmable flight volume of the UA to keep it within the flight geography; and (b) verify that the means to terminate the flight as well as the programmable flight volume functionality of the UA are operational; and 5.1.4 during the flight: (a) unless supported by visual observers (VOs), maintain a thorough visual scan of the airspace that is surrounding the UA to avoid any risk of collision with manned aircraft; the remote pilot should discontinue the flight if the operation poses a risk to other aircraft, people, animals, environment or property; (b) maintain control of the UA, except in case of loss of the command and control link; (c) operate only one UA at a time; (d) not operate the UA from a moving vehicle; (e) not hand over the control of the UA to another control unit; (f) inform the AO(s), when employed, in a timely manner of any deviations of the UA from the intended flight path, and of the associated timing; (g) use the contingency procedures that are defined by the UAS operator for abnormal situations, including situations where the remote pilot has an indication that the UA may exceed the limits of the flight geography; and (h) use the emergency procedures that are defined by the UAS operator for emergencies, including triggering the means to terminate the flight

when the remote pilot has an indication that the UA may exceed the limits of the operational volume.

Airspace observer (AO) 5.2 The AO’s main responsibilities are laid down in point A.2 of Appendix A to AMC2 Article 11 The personnel in charge of duties essential to the UAS operation.

6. Technical provisions

UAS 6.1 A UAS that is to be used in operations under this PDRA should comply with the requirements of Part 17 of the Annex to Regulation (EU) 2019/945, except that the UAS does not need to: 6.1.1 bear a Class C3 or Class C6 UAS identification on itself; 6.1.2 be exclusively powered by electricity, if the UAS operator ensures that the environmental impact that is caused by the use of non-electric UAS is minimised; 6.1.3 include a notice that is published by EASA and provides the applicable limitations and obligations, as required by the UAS Regulation; and 6.1.4 include the manufacturer’s instructions for the UAS if it is privately built; however, information on its operation and maintenance, as well as on the training of the remote pilot, should be included in the OM. Note 1: The UAS can comply with point (9) of Part 4 of the Annex to Regulation (EU) 2019/945 by using an add-on that complies with Part 6 of the Annex to said Regulation. Note 2: If the UA does not have a physical serial number that is compliant with standard ANSI/CTA-2063-A ‘Small Unmanned Aerial Systems Serial Numbers’ and/or does not have an integrated system of direct remote identification, it can comply with point (9) of Part 4 of the Annex to Regulation (EU) 2019/945 by using an add-on that complies with Part 6 of the Annex to said Regulation. Note 3: If the UAS is privately built, there may be no identification on the UA of its MTOM. In that case, the UAS operator should ensure that the MTOM of the UA, in the configuration of the UA before take-off, does not exceed 25 kg.

Table PDRA-S02.1 — Main limitations and provisions for PDRA-S02

ACCURACY OF THE REGISTRATION SYSTEMS UAS operators, when registering themselves or their certified UAS, are required to provide accurate information and update the registration data when it changes. Member States are required to keep that information and registration data accurate in their registration systems. An example of data that may change over time is: — a UAS operator address, email address, and telephone number; and — the validity of the insurance policy for the UAS. To verify the validity of the insurance policy, Member States may require, at the time of registration, the UAS operator to provide the expiry date of the insurance policy and to consider the registration invalid after that date. UAS operators, especially those conducting UAS operations for leisure, may decide to fly their UAS only for a short period; therefore, it is possible that even if the database of a registration system contains many registered UAS operators, only some of them are active. Member States may define a duration period for the validity of registration of all UAS operators and may revoke the registration number if the UAS operator does not renew that number before it expires. Member States may also decide to suspend or revoke the registration number if the UAS operator’s conduct justifies such a measure.

UAS OPERATOR REGISTRATION NUMBER (a) The unique UAS operator digital registration number that is issued by the Member States should consist of sixteen (16) alphanumerics in total, arranged as follows: (1) the first three (3) alphanumerics (upper-case only) corresponding to the ISO 3166 Alpha-3 code of the Member State of registration; (2) followed by twelve (12) randomly generated characters that consist of alphanumerics (lower-case only); and (3) one (1) character corresponding to the checksum that is generated in line with point (c). (b) The Member States should randomly generate three (3) additional alphanumerics (lower-case only) called ‘secret digits’. (c) The Member States should generate a checksum by applying the Luhn-mod-36 algorithm to the fifteen (15) alphanumerics that result from the concatenation, in the following order, of: (1) the twelve (12) alphanumerics of the UAS operator registration number defined in point (a)(2); and (2) the three (3) randomly generated ‘secret digits’ that are defined in point (b).

(d) For the Luhn-mod-36 algorithm, the mapping of the alphanumerics to the code-points should start with digits that are followed by lower-case letters, as shown below:

Alphanumeric 0 1 2 3 4 5 6 7 8 9 a b c d e f … z Code-point 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 … 35

(e) At the time of registration, the Member State should provide the UAS operator with the full registration string that consists, in the following order, of: (1) the UAS operator registration number as defined in point (a); and (2) the three (3) randomly generated ‘secret digits’, separated by a hyphen ‘-’ (ASCII code [DEC] 45).

UAS OPERATOR REGISTRATION NUMBER An example of a UAS operator registration number as defined in point (a) of AMC1 Article 14(6) Registration of UAS operators and ‘certified’ UAS is ‘FIN87astrdge12k8’, where: — ‘FIN’ is the ISO 3166 Alpha-3 code of Finland; — ‘87astrdge12k’ is an example of the twelve (12) alphanumerics, as defined in point (a)(2) of AMC1 Article 14(6); and — ‘8’ is the checksum, i.e. the result of the application of the Luhn-mod-36 algorithm to the fifteen (15) alphanumerics that result from the concatenation of the twelve (12) alphanumerics of the UAS operator registration number and the three (3) randomly generated alphanumerics (‘secret digits’, as defined in point (b) of AMC1 Article 14(6)): ‘87astrdge12kxyz’. An example of the full registration string, as defined in point (e) of AMC1 Article 14(6), to be provided by a Member State, is ‘FIN87astrdge12k8-xyz’, where: — ‘FIN87astrdge12k8’ is the UAS operator registration number; and — ‘xyz’ is an example of the three (3) randomly generated ‘secret digits’. The UAS operator must upload the UAS registration number and the three (3) ‘secret digits’ into the remote identification system of the UAS, if available, or into the electronic-identification system, if required by the geographical zone. The UAS operator should not share with anybody the three (3) ‘secret digits’ that are used to enhance the protection of the UAS operator registration number from being illegally uploaded into a UA.

DISPLAY OF REGISTRATION INFORMATION (a) If the UAS operator owns the UAS or uses a UAS that is owned by a third party, it should: display on the UA the registration number received at the end of the registration process in a way that this information is readable at least when the UA is on the ground without the need for any devices other than eyeglasses or corrective lenses. (1) register itself; (2) display on the UA the UAS operator registration number, which is received at the end of the registration process, in a way that the number is readable at least when the UA is on the ground, without using other devices than eyeglasses or corrective lenses; and (3) upload the full string, which consists of the UAS operator registration number and the three (3) randomly generated alphanumerics, into the electronic identification system, if available. (b) A QR code (quick response code) may be used. (c) If the size of the UA does not allow the mark to be displayed in a visible way on the fuselage, or the UA represents a real aircraft where affixing the marking on the UA would spoil the realism of the representation, a marking inside the battery compartment is acceptable if the compartment is accessible. (d) If a UAS operator uses a UAS owned by a third party, the UAS operator that operates the UAS should: (1) register itself; (2) display its registration number on the UA; and (3) upload the registration number into the e-identification system, if the UA is equipped with one.