Sofema Aviation Services (SAS) considers the roles, responsibilities, and scope related to the privileges of a Light UAS Operator Certificate (LUC).
Introduction – Light UAS Operator Certificate (LUC)
Light UAS Operator Certificate (LUC) is an organisational approval certificate.
- Drone operators may ask the National Aviation Authority of registration to have their organisation assessed to demonstrate that they are capable of assessing the risk of an operation themselves.
- The requirements to be demonstrated by drone operators are defined in Part C of Regulation (EU) 2019/947.
- When the National Aviation Authority is satisfied, they will issue a light UAS operator certificate (LUC) and they will assign privileges to the drone operators based on their level of maturity.
- The privileges may allow the organisation to self-authorize operations without applying for authorisation.
Privileges
The privileges may be one or more of the following:
- Conduct operations covered by standard scenarios without submitting the declaration;
- self-authorise operations conducted by the drone operator and covered by a PDRA without applying for an authorisation;
- self-authorise all operations conducted by the drone operator without applying for authorisation.
What is a LUC
The LUC is an optional operational certificate which, if obtained, guarantees some privileges to its holder.
• The highest privilege may be the possibility to start operations in the specific category without needing operational authorisation by the NAA.
• The availability of LUC certification allows speeding the process that otherwise would halt any work waiting for an authorisation to be formalized and approved.
National Aviation Authority evaluation of a LUC
An application for a LUC can only be sent to the NAA of registration.
• An UAS operator may decide voluntarily to ask its NAA to assess its organisation.
• This is to determine whether they are capable of evaluating the risk of their operations themselves.
• The requirements to be demonstrated by these operators are defined in Part C of Regulation (EU) 2019/947.
• When the NAA is satisfied, they will grant, if necessary based on the organisation’s maturity, the privilege to the UAS operator to self-assess the risk of its operation and self-authorize it eventually, without the need for the NAA to do so (depending on the various degrees of privileges granted to that organisation under the LUC).
• It is recommended that, before granting a LUC, the NAA monitors the activity of the operator by issuing some operational authorisations and assessing the understanding of the operator of the regulatory framework, including SORA, and the level of its safety culture.
Specific Operations Risk Assessment (SORA) – Safety, the risk-based approach.
The SORA is a methodology for the classification of the risk posed by a drone flight in the specific category of operations and for the identification of mitigations and safety objectives. It helps the operator to identify operational limitations, training objectives for the personnel essential for the operation (e.g remote pilots, observers, maintainers, etc..), technical requirements for the drone and to develop the appropriate operational procedures that will be part of the operator manual.
What are the LUC privileges (Article 5 of EU Regulation 2019/947)
- The NAA may assign different privileges based on the maturity demonstrated by the operator.
- This may include the following, however, different privileges may be defined:
o To conduct operations covered by standard scenarios without submitting a declaration, or;
o To self-authorise operations conducted by the UAS operator and covered by a PDRA without applying for authorisation, or;
o To self-authorise all operations conducted by the UAS operator without applying for authorisation.
Of course, by fully complying with all the conditions set by the NAA and the applicable legislation.
Note regarding PDRA – The Predefined Risk Assessment (PDRA) is an operational scenario for which EASA has already carried out the risk assessment and has been published as an acceptable means of compliance (AMC) to Article 11 (risk assessment) of Regulation (EU) 2019/947.
Note regarding Scope – The LUC holder can only conduct the operations described within the LUC terms of approval. This is why operating with a LUC certificate is both a great benefit and a responsibility.
Next Steps
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aviation, Sofema Aviation Services, SAS blogs, UAS, EU Regulation 2019/947, Unmanned Aircraft Systems (UAS), Light UAS Operator Certificate, Light UAS Operator Certificate (LUC), LUC, Specific Operations Risk Assessment (SORA), PDRA
