How will regulations benefit drone operators like Avy
A few minutes after midnight of the 30th December 2020, our compliance team submitted its application to enter the new world of the European regulations. After spending most of their winter break on it, the Avy compliance team made sure that Avy’s application was complete and ready for submission. Why so much effort into it? Well, if you missed the first part of this guide about what the regulations entail, you’ll find pt.1 of the guide here. For this edition, we asked Sara, our compliance officer, to explain a bit more about what these regulations mean for operators like Avy, how it was like up until now for us and what we’re looking forward to in 2021.
As discussed in pt.1 of the guide, the regulations adopt a risk-based approach and define 3 categories of operations (Open, Specific, Certified) dependent on their risks. Avy focuses on the Specific category which caters to riskier operations than the Open category, for example flying beyond visual line of sight (BVLOS) over sparsely populated areas. To operate in this category, the operator needs operational authorisation from the National Aviation Authority (NAA) where they are registered.
Before going any further, here is a brief glossary of some important EASA terms that will be discussed throughout the guide and were a vital part of our application process. Hereby the different possible ways to apply:
STS: Standard Scenarios are predefined operations described by EASA.
LUC: a Light UAS Operator Certificate that grants the drone operator some operational privileges, such as authorising its own operations without having to submit other applications to the NAA (ILT in the Dutch case). The LUC can only be granted to high-trustworthy operators, whose level of maturity in fields such as safety and technology is considered sufficient.
Operational Authorisation: via PDRA (PreDefined Risk Assessment), which is a simplified risk assessment provided by EASA listing the actions that the drone operator has to put in place in order to assure a safe operation. Differently from the STS, PDRA offers a greater margin of flexibility while describing and assessing the operation.
Operational Authorisation: via SORA (or other accepted) risk assessment methodology applied to the desired operation. This methodology helps to identify the risk level of the operation and the mitigation measures via different levels of risks (such as Air Risk Class or Ground Risk Class), but also via the OSO (Operational Safety Objectives based on ad hoc SAILs) needed to make the operation safe.
The enforcement of harmonised regulations all over Europe will enable safe integration of drones into the European Airspace and help the drone sector get into a more mature stage. This means giving drone operators the possibility to fly all across the EU and ensuring reliability and standardisation in operations. We’ve narrowed it down for you to get a clearer picture of how being compliant and in sync with the EU will make our lives at Avy and for our fellow citizens a lot easier, safer and more reliable.
Making it easier for drone operators
Before these new set of regulations, a drone operator in the Netherlands would need about 8 weeks to get approval from the Dutch NAA when applying for an operation that didn’t fall under its ROC. In fact, in the past Avy had to file for approval for each new type of operation we wanted to perform outside our ROC and ask a request from ILT. This process required, as a minimum, writing a scenario in the Operations Manual comprehensive of risks and mitigation measures for the operation we wanted to perform. ILT’s comments on the request would then need to be implemented and the application re-submitted once amended. This would potentially have a negative impact on Avy’s operations since the outcome of the application was unsure, causing delay in the overall process of having flight operations approved.
With the new regulations coming into force, not only will they make planning operations a lot easier, but having operational authorisations in place will make the feasibility of operations more efficient. Specifically, with an Operational Authorisation in place, a drone operator could perform the approved set of operations without needing further approval from the NAA. Even better, with an LUC, if operation is deemed safe, the drone operator could immediately self-authorise its own operations. Of course, before flying in other EASA member states, operational adjustments, as well as clear and punctual communication with the local NAA are a must for safety!
Ensuring a safer drone ecosystem
Current EU regulations stress the importance of having a Safety Management System (SMS) put in place that looks at manned aviation standards, especially in case of an LUC application, where the submission of an SMM (explained below) is required. With regards to the other authorisations, it’s not mandatory. Avy though is always keen to prove that we put safety above all.
Our Safety Management System (SMS) is based on the typical aeronautical and aviation one, and is proof that our organisation has a Safety Culture - a culture based on shared beliefs and values in relation to risks within the organisation and overall commitment to working in a safe environment. This is all described in our Safety Management System manual - SMM. The SMM is an extensive manual that dives into the way flight operations are handled at Avy, covering the roles and responsibilities of the people involved in the safety of flight operations, as well as our safety policy objectives. The SMM describes how we apply the just culture within the teams, how we handle the internal investigations we run, the reporting and the management of change. Everything has to be pragmatic and strive for safety above all, while doing everything in a way that clearly shows all risks have been taken into account and mitigated. An SMM is composed, as minimum, by:
- Safety risk management: defines the way Avy deals with risks and management of risks, especially with mitigation measures since risks are everywhere. However, what distinguishes one company from another is the way in which they mitigate the risks in such a way that makes it safer or not, especially via two pivotal tools: the Operational Risk Assessment and the Emergency Response Plan. Through the Operational Risk Assessment we can automatically be aware of the risks we may face for each operation we’re going to perform. The Emergency Response Plan is used as a complimentary document that ensures that the pilot and all flight crew are ready to act in case of an emergency. At Avy, all our pilots are trained for this.
- Safety assurance: here we assure that the safety policy is effective and implemented correctly. A special attention is given to change - when change is performed within the company, like a change in pilot in command or the type of batteries we use, this all needs to be noted, monitored, and approved as an important change that could lead to potential risks. Thanks to its Management of Change (MoC), Avy makes sure that we perform everything in the safest way possible and do not perform any operations until we know for certain that the big change that has been implemented in our company is a safe one.
- Auditing process: in our SMS we define and conduct internal and external audits of the company. In this way we assure the EU Commission and the ILT that we comply with the rules, and, more importantly, that what we state in our SMM is in fact put in place.
- Training: This is vital to any organisation and Avy as a company really believes in continuous learning and training of pilots. The training can range from communication, to regulations and safety emergency procedures.
As stated by Sara, our compliance officer,
"To ensure safe operation in manned airspace, one of the key factors from the new regulations is a harmonised system where safety measures and protocols have to be implemented according to the European regulation, no matter the country..”
Compliance for all operating drones
For any operation we want to perform, a ConOps (Concept of Operations) is developed using the SORA methodology to define the types of risks (ground & air) of the intended operation and evaluate the type of OSO (Operation Safety Objectives) required by the SAIL (Specific Assurance & Integrity Level) the operation falls under. Whereas SAIL is a level calculated to determine how risky an operation will be, OSOs are a list of objectives that a company needs to comply with to ensure a safe operation. Alternatively, a predefined risk assessment (PDRA) will be used when more standard operations are to be carried out. Read our safe & SORA blog to find out more about how OSOs play a big part in how a SAIL is obtained and with determining the level of robustness required to ensure a safe and reliable operation.
We couldn't have phrased it better than Stephan Van Vuren, AirHub's co-founder and drone consultant,
"We strongly feel that the EU regulations will mark a new era for the professional drone industry”
Indeed it’s a new era for drone operators and we're just getting started. One thing for sure is that 2021 will be about gaining maturity and creating trust with society through harmonisation to ensure a future with safe and reliable drone operations throughout the EU.
EASA FAQ on LUC
EASA FAQ on operational authorisation
For more information about ILT
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