Enaire, the airspace manager in Spain, updated yesterday, December 11, some general UAS geographic zones for the protection of facilities and infrastructures in which essential services are provided for the community, as established in article 39 of Royal Decree 517/2024.
Therefore, since yesterday, if we access the viewer of the UAS geographic zones provided by ENAIRE as an official data source (drones.enaire.es), we will be able to see some transport or energy generation infrastructures that are considered critical shaded in red. Remember that the distance specifications set out in the aforementioned article 39 of RD 517/2024 must be met with respect to this type of infrastructure for all UAS or unmanned aircraft.
Let us remember that in point 2 of the indicated article, the protection zones of this type of infrastructure are detailed, depending on their volumetric typology, that is, whether they are linear or not, establishing a minimum distance and height of overflight. This means that a vault is established, called a protection zone, in which drone operations cannot be carried out, if there is no express authorization from the owner or the manager responsible for the installation or infrastructure and, where appropriate, the conditions determined by the latter must be met.
Enaire, through drones.enaire.es, once some of these general UAS geographic zones have been loaded, expressly indicates that flight permission must be requested from the manager if drone operations are carried out within the protection zone established by article 39 or by the conditions established in the Enaire viewer itself.
Carrying out a quick assessment on drones.enaire.es in the area where we are based, and where we carry out the most operations, and where we know the best, we find that many infrastructures defined in article 39 are missing without being marked. The article itself defines these areas as energy plants, petrochemical or chemical industries, refineries, fuel supply and depot services, port and railway infrastructures, roads and other transport infrastructures, infrastructures for water, gas, and electricity supply and distribution services, information and communications technology infrastructures or even public or private hospitals as well as public health centres.
For the moment, in this quick assessment of the viewer, we note that ADIF facilities (such as railway transport facilities) or Repsol infrastructures, such as the Petronor facility in Muskiz (Bizkaia) are shaded.
In this first look we miss road transport facilities, such as high-capacity motorways or dual carriageways, main roads, hospitals, port gas storage facilities or Enagás facilities in Bermeo (for example) or the Boroa thermal power station also in Bizkaia. Rail transport facilities such as the Bilbao Metro or the FEVE lines, and even tram lines, would also be missing.
We understand that the viewer will be updated to include this type of facilities or infrastructure in the successive reviews that are carried out.
However, the fact that they do not appear in the viewer does not mean that current legislation should not be complied with and that they should not be treated as geographic areas of UAS with the limitations applied by article 39.
That is why we appeal to the responsibility of UAS operators and their good work, and to respect these areas even if they do not appear in the viewer, because not all of them that should be are there.
