The European Aviation Safety Agency has published new guidelines for drone or UAS operations within the open and specific categories.
These guidelines, dated 17/07 as document No. 3, should not be construed as guidance material (GM) adopted pursuant to Article 76(3) of Regulation (EU) 2018/1139. They are not legally binding and should be considered solely as a working document summarizing and disseminating experience with the implementation of the drone regulatory framework to facilitate its application by competent authorities, operators, and addressees of Regulations (EU) 2019/945 and 2019/947.
The content of these guidelines should not be interpreted or used to contradict or modify the requirements of the aforementioned regulations, nor should they be used, in themselves, to justify the opening of non-compliance reports during oversight and standardization activities carried out by the Agency or national competent authorities.
Content has been published according to the following index:
1.- Calculating the distance within visual range (VLOS).
2.- Within the open category, guidelines for overflight by moving vehicles are provided, primarily referring to high-capacity roads or highways, other types of roads, and railways.
3.- Guidelines for determining airborne risk in the SORA assessment.
4.- Operational authorizations regarding generic versus precise locations.
1.- Operating an unmanned aircraft in VLOS means that the remote pilot can clearly assess the airspace to detect the presence of other aircraft, clearly see the UAS, and avoid approaching other aircraft (manned or unmanned), obstacles, or people that may pose a hazard.
VLOS distance is affected by several factors, such as:
— Visibility: The operational area and weather conditions must allow for direct visual contact with the UAS and detect the presence of other aircraft in the area where it operates. The recommended minimum visibility is at least 5 km;
— Size of the UAS;
— Characteristics of the UAS, such as the aircraft's color (relative to its difference from the background color) and the brightness of its lights.
When planning a VLOS operation, the VLOS distance should be measured as the straight-line distance between the remote pilot and the UA.
There are various methods and formulas that allow for a quantitative assessment of the VLOS distance. The document proposes a formula for fixed-wing and multirotor unmanned aircraft (UAS), based on the evaluation of two parameters and setting the VLOS to the lower of the two.
— Maximum distance at which the remote pilot can detect the UA's position and orientation, based on its size, referred to as "attitude line of sight" (ALOS); and
— Distance at which other aircraft can be visually detected and sufficient time for an evasive maneuver, referred to as "detection line of sight" (DLOS).
Formulas for calculating VLOS distance based on ALOS and DLOS are introduced.
2. Implementing Regulation 2019/947 does not explicitly address the risks associated with overflight of moving vehicles in the open category. However, the regulation contains some generic safety objectives to ensure that safety margins are always maintained during UAS operations.
In general terms, the overall risk can be defined as the combination of the frequency (probability) of an event and the associated hazard level.
Regarding hazards, the new document assesses the following categories:
- Direct hazards generated by the impact of a drone against the roof or windshield of a moving vehicle.
The severity of this hazard is primarily influenced by the kinetic energy transmitted to the vehicle (=> weight of the drone and speed of the vehicles).
- Indirect hazards generated as a result of a drone impact. For example, traffic accidents occurring on a busy highway as a result of a driver abruptly turning the steering wheel in an attempt to avoid impact with a drone or its debris. Typically, indirect hazards are more relevant for roads than for other types of infrastructure and are primarily influenced by vehicle speed, the mass of the drone, the volume of traffic on the road, and the presence of fences around the road (as these would impede the rapid removal of drone debris).
Regarding the probability of a drone accident in the open category, there are currently no quantitative assessments available, so the draft Annex F4 of SORA could be used as a reference. According to this document, the operational failure rate for a drone in SAIL II could be on the order of magnitude from 10 to the minus 2 per flight hour.
Although in some specific cases a SAIL II drone could differ significantly from drones in the open category, it can be assumed with an acceptable level of approximation that the operational failure rate is similar.
The riskiest scenario occurs in operations over busy highways and roads. For this reason, some additional considerations and mitigation measures are required. Operations over railways still require certain considerations and mitigation measures.
These additional considerations and measures are described in the new guidelines.
Operations over heavily trafficked inland waterways are not considered particularly risky, and the available equipment is considered sufficient.
While the ultimate goal is to protect vehicles and their occupants, it is impractical to introduce provisions based on the intrinsic protection offered by vehicles, as they could travel at higher speeds than UAS in the open category and because the level of intrinsic protection of vehicles varies significantly depending on their type (e.g., motorcycles versus vans). Consequently, the material developed does not directly address vehicle overflight, but rather the overflight of infrastructure (e.g., roads and railways).
Finally, EASA Member States, as is the case in Spain with the introduction of UAS geographic zones in Royal Decree 517/2024, may use geographic zones, pursuant to Article 15 of the Regulation, to address the risks associated with the overflight of moving vehicles by introducing specific limitations or conditions for UAS operations on roads and railways.
UAS pilots and operators are expected to benefit from the newly published guidelines, as they will increase their awareness of potential risks and provide them with best practices.
It should also be noted that, where a geographic zone exists, the restrictions and conditions it introduces will prevail over the content of this document.
3. The rapid advancement of unmanned aircraft systems technology has opened new frontiers in aviation, offering unprecedented opportunities for various stakeholders, including operators, service providers, third-party vendors, and third parties. However, the safe and efficient integration of UAS operations, particularly beyond visual line of sight (BVLOS) operations, into EU airspace presents significant challenges. This guide aims to address these challenges by providing best practices and considerations for the safe conduct and approval of operations in different classes of airspace, including traditional airspace and the emerging concept of U-space.
The new guidelines are based on Specific Operations Risk Assessment (SORA) 2.0 and are aligned with SORA 2.5.
It is worth noting that, starting in June 2025, a SORA 3.0 version is being developed within the Joint Authorities for the Regulation of Unmanned Systems (JARUS) group with the aim of improving Annexes C and D regarding aviation risk. These guidelines may need to be revised when this new version is published. These guidelines are not legally binding and are considered solely a working document summarizing and disseminating experience in the application of the UAS regulatory framework to facilitate implementation by competent authorities, operators, and addressees of the Delegated and Implementing Regulations. The content of these guidelines shall not be construed or used to contradict or modify the requirements of previous regulations, nor shall they, in themselves, be used to justify the issuance of non-compliance notices during oversight and standardization activities conducted by the Agency or national competent authorities.
The newly published document serves as guidance on airborne risk assessment for stakeholders involved in the planning, execution, or approval of UAS BVLOS operations. Key sections of the document include:
⎯ How to conduct an assessment of the airspace where the UAS operation is conducted.
⎯ Considerations on the use of strategic and tactical mitigations.
⎯ Annexes: A collection of complementary materials and resources to support stakeholders and provide educational material.
4. According to Article 12 of the UAS Regulation, a competent authority may grant a generic operational authorization (i.e., an authorization carried out at generically identified locations, in accordance with the conditions set out in the authorization). Unlike a generic operational authorization, an operational authorization limited to locations identified by geographic coordinates will be referred to as a precise operational authorization.
The UAS operator must, in any case, check whether the Member State where the operation is being conducted has published a geographic zone within the area of operation, in accordance with Article 15 of the UAS Regulation, that requires a flight authorization (for example, this could be the case for areas covered by U-Space). It is important to note that a flight authorization to enter a UAS geographic zone, pursuant to Article 15, should not be confused with an operational authorization based on the SORA risk assessment.
You can download the document at the following link:
https://www.easa.europa.eu/en/downloads/139435/en
In addition, EASA, with the support of the Airworthiness Working Group of the Technical Body for UAS (TeB), has published a comprehensive airworthiness guide for unmanned aircraft systems (UAS) that do not require certification under Regulation (EU) 748/2012 (Part 21).
The new methods of compliance (Proposed MOC for OSO No. 2 and MOC for OSO No. 8), currently under consultation, complete the technical framework necessary to allow the operation of drones under a declarative framework (those classified as Specific Assurance and Integrity Level (SAIL) III in the Specific Operational Risk Assessment (SORA).
These methods of compliance cover organizational aspects, flight manual, structures, and configuration control, with particular attention to design change management. Interested parties are invited to submit their comments until September 12, 2025.
For SAIL IV, UAS designers must receive a Design Verification Report (DVR) for their product. To facilitate this process, EASA has published a reference table to assist DVR applicants in proposing compliance measures for light UAS with Special Condition. The table describes how applicants can meet each Special Condition requirement, using compliance measures published by EASA and recognized standards. The table, which also provides information on ongoing activities in this field, is a living document and will be updated by EASA when significant new material becomes available.
This document can be consulted at the following link:
https://www.easa.europa.eu/en/downloads/139435/en
