CAA EASA Categories – Delayed Until 31st Dec 2020

Open Category – A1 – fly ‘over’ people

▪ A1 (fly ‘over’ people) – Operations in subcategory A1 can only be conducted with unmanned aircraft that present a very low risk of harm or injury to other people due to their low weight (less than 250g), their type of construction, or because they are a ‘toy2 ’ (i.e. they are ‘inherently harmless’). However, flight over open-air assemblies of people is not permitted.

This is for a C0 class drone or you can fly with no intentional flight over uninvolved persons with a C1 class drone.

C0 Unmanned Aircraft System

C0 (toys) are toys that have a MTOM of no more than 250g.

Class C0 – (can be flown in all subcategories) Very small unmanned aircraft, including toys, that:

▪ are less than 250g maximum take-off mass

▪ have a maximum speed of 19m/s (approx. 42.5 mph)

▪ are unable to be flown more than 120m (400ft) from the controlling device

The drones and types of operations have been deemed to present a very low risk of harm or injury to other people due to their low weight, type of construction or have been deemed ‘inherently harmless’. However, flight over open-air assemblies of people is not permitted.

There is also a C0 (not a toy) which is effectively an Unmanned Aircraft System with a MTOM of no more than 250g but is fitted with a camera (or sensor). The same standards apply as above, however, to fly this Unmanned Aircraft System in this subcategory you will have to complete the DMARES (Drone and Model Unmanned Aircraft System Education Service) to get your Flyer ID and affix an Operator ID to the Unmanned Aircraft System.

With any C0 Unmanned Aircraft System, you can overfly people as long as it is not over an assembly of people. Examples of an assembly of people are: sport, cultural, religious or political events; beaches or parks on a sunny day; commercial streets during the opening hours of the shops; and ski resorts/tracks/lanes.

These limitations are designed to minimise risk by avoiding circumstances where people are unable to move out of the way of the drone if it goes out of control.

DJI Mavic Mini is a C0 Transitional Aircraft – overflight of uninvolved people permitted but not crowds or events etc

C1 Unmanned Aircraft System

C1 are Unmanned Aircraft System that are less than 900g MTOM or have no more than 80 joules of kinetic energy to a human head on impact. They also must not fly more than 19m/s (42.5 mph), needs a remote ID, will have noise limitations and geo-awareness.

You can also fly home or privately built Unmanned Aircraft System in the A1 category if the MTOM is less than 250g and flies no more than 19 m/s. 

To fly a C1 Unmanned Aircraft System in the A1 subcategory you will have to complete the DMARES (Drone and Model Unmanned Aircraft System Education Service) to get your Flyer ID and affix an Operator ID to the Unmanned Aircraft System

  • If a class C0 or C1 aircraft has its ‘follow-me’ mode activated, it may be flown up to a distance of 50m from the remote pilot, even if this means that the aircraft is no longer within visual line of sight

Privately built – less than 250g and max speed less than 19 m/s

If you have a self built Unmanned Aircraft System that has less than a 250g Maximum Take Off Mass then you can fly over uninvolved people, but not over crowds at sport events, bus stops etc.  If your privately built Unmanned Aircraft System has a camera on it, you will need to get an Operator ID and affix it to the Unmanned Aircraft System.

FLY your ‘legacy’ sub 500g aircraft in the Open Category A1 (Transitional Period) until 2022, after which you will need to purchase and fly a C1 class aircraft. You may not fly overhead uninvolved people. UAS in this weight Class; Parrot Anafi, DJI Spark, 

Open Category – A2 – close to people

The A2 subcategory will allow you to fly closer to people if you hold an A2 Certificate of Competency (A2 CofC) in the UK and are flying a C2 class Unmanned Aircraft System.

You’ll be able to fly down to 30m of uninvolved people, or down to 5m if the Unmanned Aircraft System has been switched to a low-speed mode.

The only Unmanned Aircraft System you can fly in this category with the CofC is the C2 class Unmanned Aircraft System which is Unmanned Aircraft System with a Maximum Take Off Mass of no more than 4 kg.

C2 Unmanned Aircraft System

C2 class Unmanned Aircraft System need to have less than a 4 kg Maximum Take Off Mass, be ‘safely made’ as determined by EU manufacturer standards, it needs noise limitations, a remote ID and a form of geo awareness.

It also needs a low-speed mode which limits the maximum speed of the Unmanned Aircraft System to 3 m/s (approx 6.7 mph).

Please note: There are currently NO EXAMPLES of a C2 class Unmanned Aircraft System on the market at the time of publishing this web page.

In the transitional period an Unmanned Aircraft System with a mass of less than 2kg will be able to be operated in subcategory A2, as if it was a class C2 device, but only down to a minimum horizontal distance of 50m from people. In addition, the remote pilot will be required to have been tested to a competency level that is at least equivalent to that required for operation within the A2 subcategory (i.e. the ‘A2 CofC).

A2 Certificate of Competency (A2 CofC)

To get the A2 Certificate of Competency (A2 CofC) that will allow you to fly C2 class Unmanned Aircraft System down to 30m, or 5m in a low-speed mode, you firstly need to do the DMARES online examination to get the basic RP competency, and then you will need to take an additional theory test with an RAE (Recognised Assessment Entity).

Please note: RAE is what NQE’s (Nationally Qualified Entities) will transition over to teach A2 CofC courses and General Visual Line of Sight (GVC) courses.

This will mean learning a syllabus and then sitting a 30 question closed book examination which you will have a minimum of 75 minutes to complete.

There is no practical flight test or operations manual required as part of the course, however, the student will need to have completed a period of practical flight training, either under the guidance of an RAE or under self-monitored circumstances.

The student must declare in writing that they have completed the DMARES and flight training before taking the A2 CofC written examination.

As soon as you pass the written exam and the CAA implements the regulation you’ll be instantly qualified to fly in the A2 category with a C2 Unmanned Aircraft System without having to apply to the CAA.

You need to be aware that you will still have to log all flights and keep flight records (we provide flight logging forms), should you have an incident or accident you’ll be investigated by the CAA. So you will still need to do Risk Assessments which we will provide templates to follow.

Your qualification lasts for 5 years, after which you’ll have to renew it.

Open Category – A3 – far from people

The last subcategory in the Open category is the A3 which is where you must not fly within 150m of residential, commercial, industrial, or recreational areas and no uninvolved people must be present within the area of flight. This is where all legacy UAS will have to be flown in the future (around 2022) if they do not have a C Rating.

This subcategory applies to C3 and C4 Unmanned Aircraft System.

C3 Unmanned Aircraft System

C3 class Unmanned Aircraft System must comply to the Delegated Regulation standards (EU manufacturing standards) which include that the Unmanned Aircraft System must have a MTOM of less than 25kg, a remote ID and must have geo awareness.

To fly a C3 Unmanned Aircraft System in the A3 subcategory you will have to complete the CAA UK DMARES (Drone and Model Unmanned Aircraft System Education Service) to get your Flyer ID and affix an Operator ID to the Unmanned Aircraft System

C4 Unmanned Aircraft System

C4 class again must comply to the EASA delegated regulation standards, be less than 25kg MTOM but are basically traditional model Unmanned Aircraft System with no automation.

To fly a C4 Unmanned Aircraft System in the A3 subcategory you will have to of completed the DMARES (Drone and Model Unmanned Aircraft System Education Service) to get your Flyer ID and affix an Operator ID to the Unmanned Aircraft System.

Please note: You can also fly home built or privately built Unmanned Aircraft System that are less than 25kg MTOM in the A3 subcategory

Frequently Asked Questions

Are the Open category separation distances from uninvolved persons still based on a ‘bubble’ around the person, so we can fly over the top of them?

No, the separation distances are all based on ‘horizontal separation’ (i.e. like a ‘cylinder around the person) and they must not be overflown at any height.

I currently hold a ‘standard permission’ (also known as a ‘PFCO’) that was issued by the CAA. What should I do after the new EU UAS regulations become applicable?

The first point for you to note is that your permission will still remain valid until its expiry date and you will not suddenly become ‘illegal’ on 1 November 2020. So, you can continue to operate as normal. When your permission’s expiry date approaches, you basically have two choices:

• You can renew your permission in the same way you have done in previous years; or,

• You can ‘opt out’ of the CAA’s oversight and operate within the limits of the Open category If you renew, nothing changes, other than the new document you receive will be called an ‘operational authorisation’ rather than a permission, but it will contain the same privileges as you currently hold.

If you decide to operate within the Open category instead, you will then be subject to all of the limitations of the Open category, dependent on which subcategory you operate in. Depending on the types of flights you wish to undertake, your remote pilots may be required to undertake some additional competency testing, or you may have to purchase a different type of unmanned aircraft.

Example; you can just operate under the A2 CofC but no overflight of unintended people and have insurance 785 / 2004 for commercial operations.

I’m unsure about which category or subcategory that I fit into; how do I work this out?

You need to approach the ‘question’ from one of two angles, either:

• What type of flying/where do you want to fly? – then look at the subcategory (A1, A2 or A3) that permits this.

•A1 Transitional UAS are UAS less than 500 grams

You can fly in the A1 subcategory with any UAS that is less than 500g close to uninvolved people (no minimum horizontal limit) but you must not intentionally fly over them. 

(Examples; DJI Spark / DJI Mavic Mini / Parrot Anafi / DJI Air v1)

You must have taken the A2 CofC though to fly under the A1 Transitional weight class

 

• What type/weight of unmanned aircraft do you have? – then look to see which subcategory your aircraft falls into and hence, work out what flying you can perform.

If the type of flying you wish to conduct falls outside these parameters, or you cannot do the type of flying you want with the unmanned aircraft you own, then you will either have to replace your unmanned aircraft with a more suitable type, or conduct your operation in the specific category and apply to the CAA for an operational authorisation.

What are the limitations regarding flight near or over vehicles, vessels and structures as they are not mentioned?

The regulations are focussed on the safety of uninvolved persons and so there are no specific minimum distances set down for separation from ‘vehicles, vessels and structures’. BUT, this does not imply a complete ‘free for all’ as vehicles, vessels and structures will in many cases still have persons inside them which need to be protected. There are two points to take note of however;

• The current ‘endangerment’ regulation in the Air Navigation Order (article 241), still applies, and so it is an offence to ‘endanger’ such property with an unmanned aircraft.

. • The prescribed separation distances from uninvolved persons still apply to persons that are occupants of any vehicle, vessel or structure. So, you still have to apply the relevant limitations for separating from persons, unless you can be certain that they are unoccupied or, in the case of structures, you can be certain that the occupants will be protected because of how the structure has been manufactured.

Of course, the overall security and privacy situation must also be considered, as there will be a number of buildings where it would be inadvisable, from a security or privacy standpoint, to be flying close to without first obtaining permission to do so.

What limitations are there for night flying in the open category?

There are no specific limitations but remember that only VLOS flight is permitted in the Open category. Therefore, you must keep the unmanned aircraft within your visual line of sight at all times. Clearly, this means that at night the aircraft must be sufficiently illuminated for the remote pilot to be able to see it and carry out his/her collision avoidance responsibilities.

Are there any plans to allow current, & recently expired PFCO holders, or Model association members with an appropriate “Achievement Award” to be exempt from the requirement to undertake the A2 CofC test in order to fly in the A2 subcategory?

No. The A2 subcategory is part of the Open category and so has no oversight by the CAA. Therefore, any person operating on the Open category must comply with the full requirements of the category.

Can a current NQE certificate (or ‘full recommendation’) of remote pilot competency be used after 1 November 2020 to fly against another operator’s PFCO?

Yes, if it is being applied to a current permission or one that is renewed as an operational authorisation and its text allows this level of competency. The ‘operator/permission holder’ will hold the responsibility to ensure all remote pilots can operate safely and legally; within this, we would expect any remote pilot to ensure that he/she is sufficiently conversant with the new regulations. Note: In the future, there will come a point in time where we will require all ‘NQE full recommendations’ to have been converted into a GVC.

Some RAEs will be offering a ‘conversion course’ for this. While the exact timescale has not yet been finalised, we expect this to be either 3 or 4 years from now (1 Nov 2023 or 2024), based on the fact that the GVC is required to be renewed every 5 years. CAP 722 will detail this when it is amended in October.

Can an existing UAS be ‘retrospectively marked’ with a ‘C’ Class from 1 November 2020 (e.g. will my 3kg drone will become a ‘C2 Class’ aircraft)?

No, this is completely wrong! The ‘CE’ Class markings do not work retrospectively. So, a current 3kg aircraft, for example, will never become a C2 model; it will only ever be ‘a legacy unmanned aircraft that weighs 3kg’. In the same fashion, a current 800g aircraft will not become a C1 model; it is just ‘a legacy unmanned aircraft that weighs 800g’.

In order to be given a particular Class marking, the aircraft must have been designed and manufactured to the relevant standards of that class marking. The only way you can get an aircraft with a ‘CE class marking’ is to buy one that has this marking.

The ‘legacy unmanned aircraft’ do not suddenly become unusable however:

• In the case of the 3kg ‘legacy aircraft’ it can only be operated in the A3 subcategory (far from people) within the Open category, or flown in the Specific category in accordance with an operational authorisation granted by the CAA.

• In the case of the 800g ‘legacy aircraft’, it could be operated in the A2 subcategory until 30 Jun 2022, using the transitional provisions, provided that its remote pilot has passed the A2 CofC theoretical test.

Will there be any changes or further training required with other existing qualifications/permissions in order to comply with the new classes or categories (such as BVLOS operations etc)?

No, if you wish to continue with the privileges you have today, you simply renew your current permission/exemption at its expiry date and continue to operate in the Specific category. This is the same as people will have done in previous years, except that the new document you receive will be called an operational authorisation.

I’ve read social media blogs from people saying that the GVC is equivalent to a PFCO and that this is all I need to operate. Is this correct?

No, it is not correct. Your ‘blogger’ has misunderstood their purposes and the PFCO and the GVC must not be viewed in the same context.

• The GVC is a remote pilot competency qualification; its nearest previous equivalent would be the ‘NQE full recommendation’

• The PFCO is a type of operating permission, which is a written authorisation from the CAA to conduct a type of UAS operation; under the new regulations, these are called ‘operational authorisations’

So, in order for a UAS operator to obtain an operational authorisation, all of the remote pilots they use will need to have reached a suitable level of competency for that operation. The GVC is a simple way of expressing a remote pilot’s competence to fly any VLOS operation.

Note.- From November 2020, any new operators wanting the equivalent privileges of a PfCO, will need to apply for an operational authorisation and follow the requirements set out in UKPDRA-01 which will be detailed in the update to CAP 722 when it is published in October. This will require remote pilots to complete the GVC and the operator will need to submit their operations manual to the CAA in a similar way to which they do currently. The operator will then be issued with an operational authorisation with equivalent privileges to those an operator would gain today from a PfCO.

Now that the commercial operations ‘trigger’ for getting a permission from the CAA has gone, can I just tear up my permission and carry on without any reference to the CAA?

It very much depends on the types of operation that you ‘want to do’, and on the aircraft that you are ‘doing it with’. If you can work within the various limits of the Open category, then you are free to do so without requiring you to obtain CAA authorisation, but bear in mind that to remain within the Open category, there are a number of limitations, both on the size or manufacturing standard of the unmanned aircraft and the competency requirements. These may either prevent you operating, or require you to go to additional expense (by having to purchase a different aircraft and/or undertaking an additional competency test) in order to do so. If you need to operate in a residential, commercial, industrial or recreational April 2020 | CAP1789 45 area (what we currently term ‘congested areas’) you will still need an authorisation from the CAA.

My current aircraft already has a setting on it where I can reduce its speed. Does this mean that I can fly in the A2 subcategory down to 5 metres from uninvolved people?

No, it doesn’t. The ‘low speed mode’ that is referred to in the A2 subcategory is a mode that is specifically designated for the C2 Class of unmanned aircraft. Any other ‘reduced speed operation’, whether electronically or physically limited, close to uninvolved persons would need to be the subject of an operational authorisation and cannot be ‘automatically’ used in the Open category. So, for the device that you have mentioned above, unless the UA has been marked as a ‘C2 class’ UA, then these capabilities are not relevant (nor is any form of ‘skilful manoeuvring’). Existing aircraft will not be able to operate at the low speed mode distances.

What are the separation requirements from uninvolved people in the A3 subcategory?

There should not be any uninvolved persons “endangered within the range where the UA is flown during the entire time of the UAS operation”. This means that there should not be anyone that is not part of the flight in any part of the area that the aircraft is planned to be flown, and people should be at least 50m away from the ‘boundary’ of the flying area.

If an uninvolved person ‘strays’ into the flying area, then the aircraft must be moved away from that uninvolved person immediately. The 1:1 rule (see next question) allows remote pilots to make a quick and simple assessment of the relative risk.

However, if the person stays in the operating area (as opposed to just ‘passing through’), then the flight would need to be stopped.

Some people have mentioned a ‘1 in 1 rule’. Can you explain what this is?

The ‘1:1 rule’ is offered in the AMC/GM documents as a simple ‘rule of thumb’ (as opposed to an exact rule in law) which can be used to quickly work out what separation from uninvolved persons is safe enough in the short term. It is based on the relationship between the unmanned aircraft’s height and its distance from the uninvolved person (the 1:1 line) and works as follows:

A2 subcategory – (for C2 aircraft only) when operating in low speed mode within 30m of uninvolved persons, remote pilots should aim to maintain a horizontal separation distance that is greater than, or equal to, the aircraft’s height (using the same units of measurement) E.g. if the aircraft is at 10m height, it should be kept at least 10m horizontally away from uninvolved people. Operations where the aircraft’s height is greater than the separation UAS Height 1:1 line (h=d) (h) Distance from persons (d) Above (high risk) Below (lower risk) April 2020 | CAP1789 46 distance (i.e. above the 1:1 line) should be avoided or kept to the absolute minimum time necessary, due to the increased risk. Don’t forget that the absolute minimum separation distance when in low speed mode is still 5m horizontally.

A3 subcategory – The 1:1 rule is a short-term separation measure for dealing with unexpected issues. If the aircraft is above the 1:1 line (i.e. closer to the person than its height), then it must be moved further away quickly, or its height reduced, until below the 1:1 line. If the aircraft is below the 1:1 line, then the remote pilot can continue to monitor the situation until the person has vacated the operating area. But the separation from any uninvolved person must not be reduced below 50m horizontally at any time.

I have previously held a PFCO but it has now expired. Can I use my previous remote pilot competency assessment instead of a GVC to obtain an operational authorisation based on a PDRA after 1 November 2020?

No. No credit will be given for permissions that have expired. Any new application must comply with the remote pilot competency requirements that are stated in the relevant PDRA.

Am I compelled to use the SORA when I apply for an operational authorisation?

No, you can still use the OSC methodology, as detailed in CAP 722A after 1 November 20 if it is more appropriate to your operation. Article 11 sets out the specific points that must be contained within an operational risk assessment. You may choose to use your own methodology if you wish, provided that it complies with Article 11, but it should be noted that the subsequent assessment may take longer to assess by CAA staff, and hence incur an increased charge.

In CAP722B it states that I can fly at extended visual line of sight (EVLOS) if I undertake module 1. Can I add this onto my existing certificate of competency that I have obtained from my NQE?

No, you will need to upgrade your NQE recommendation to a GVC prior to undertaking module 1 of the GVC. Some RAEs will be offering an upgrade course to convert your certificate of competency to a GVC to save you from having to repeat things you learned during your NQE training.