The non-sense of requiring prior authorisation for each new flight location for low-risk operations in the Specific category

The idea behind an operational risk assessment, whether it is a SORA or a PDRA, is to describe the intended operations in full detail and to assess the risks involved with these operations. The operator may choose to apply certain mitigations related to ground risk (e.g. parachute) or air risk (e.g. submitting a flight plan and maintaining two-way radio communication with ATC during the flight), which could lead to a reduction of the overall risk level (SAIL) of the operations, allowing the operator to prove compliance with the operational safety objectives (OSOs) at a lower level of robustness.

Most measures implemented by the operator are documented in the different parts of the Operations Manual, but also in additional documents such as pre- in- and post-flight checklists, emergency response plans, training documents, flight plans and compliance evidence documentation.

The SORA safety case / PDRA table, Operations Manual, flight document templates and compliance evidence documents are sent to the civil aviation authority. Once positively assessed, the operator receives an operational authorisation (OA) for the ‘operational scenario’ that they have created based on their risk assessment and documentation.

However, the type of OA received by the operator (‘generic’ or ‘precise’) depends on the Member State issuing the OA, even though the operational scenario in both states is exactly the same. Even for low-risk operations in the specific category (e.g. PDRA-S01), some Member States only issue a precise OA, disregarding the text on page 297 of the Easy Access Rules for Unmanned Aircraft Systems – Revision April 2024, which states that “a generic operational authorisation may be relevant for operations conducted according to PDRA-Sxx, since the conditions are similar to the ones of the declarative STS and it is relatively easy for the UAS operator to ensure compliance with those conditions”.

Recently a template for a Cross-Border Operations Manual has been published, requiring the operator to describe (for every flight location!) the general operational limitations, environmental conditions and technical operational limitations, which is basically a copy and paste from other parts in the Operations Manual, creating many unnecessary additional pages to their already long list of documentation. Additionally, the operator is required to describe specific procedures for updated mitigation measures in the flight area. But why? The mitigations have already been described during the SORA process and the drone maps of authorities clearly show any additional geographical requirements, which the operator can perfectly assess themselves prior to the operation. The relevant procedures have already been included in the Operations Manual. Again, this is a copy and paste of information that already exists. And what if geographical zones are updated? In this case, the Operations Manual shows old information in relation to the affected flight location, requiring the operator to update the manual from time to time, which is really time-consuming.

Whilst issuing a precise OA for operations with a higher risk profile (e.g. long-distance BVLOS operation) makes a lot of sense, this all seems a bit too much for low-risk operations (SAIL II or lower) in the Specific category. The operator is perfectly able to assess and prepare their flight at a new flight location for these operations, even when it is in a geographical area. A switch should be made to only generic OAs in the low-risk spectrum of the Specific category.