In the previous part of our series, we covered SORA methodology, which serves for individual risk assessment planned operations in a specific category of drone operations. The result of this process is usually operating permit issued by the Civil Aviation Authority.
However, not every operating authorisation has to be limited to one specific location or single operation. The European Aviation Safety Agency (EASA) in its explanatory materials also allows for the possibility of so-called Generic Operational Authorisation, which can be a significant simplification for professional operators.
What is the generic operating authorization based on?
Concept generic operating authorization is based on explanatory materials published by the European Aviation Safety Agency (EASA), specifically documents AMC (Acceptable Means of Compliance) a GM (Guidance Material) to Regulation (EU) 2019/947.
AMC represent acceptable means of demonstrating compliance with the requirements of European aviation regulationsThey are not legally binding, but their use creates a presumption that the operator has met the relevant regulatory requirements.
GM are explanatory and methodological materials, the purpose of which is to explain how individual provisions of European regulations should be correctly interpreted and applied in practiceAlthough neither GM is legally binding, it provides significant guidance for both operators and aviation authorities when assessing applications for operating authorization.
It is in these documents that EASA describes the concept of a generic operating permit as one of the possible ways of issuing operating permits in a specific category.
What is a generic operating authorization?
A generic operating authorization is a form of operating authorization that not issued only for a specific location or individual operation.
Instead of a precise location definition sets out the conditions under which an operator may conduct similar air operations at different locationsThe decisive factor is therefore not the specific address or geographical coordinates of the flight, but whether the planned operation meets the conditions specified in the authorization.
Conditions set out in the authorisation
Conditions may include, for example:
- type of airspace,
- population density,
- maximum flight altitude,
- operating area and protective zones,
- technical and operational conditions of operation.
Before each flight, the operator is obliged to verify that the specific location actually meets all the specified conditions.
What are the benefits?
The biggest advantage of a generic operating permit is higher operational flexibility.
For example, a company that regularly inspects photovoltaic power plants, bridges, railway infrastructure or buildings throughout the Czech Republic does not need to apply for a new operating permit just because the location of the contract changes. If the conditions set out in the generic operating permit are met, similar operations can be carried out at different locations without repeated approval of each individual location.
This is significantly reduces administrative burden a speeds up order planning.
When can a generic operating authorization be used?
According to EASA's explanatory materials, a generic operating authorisation is particularly appropriate when the conditions of the planned operation are clearly defined and the operator is able to reliably assess whether they are met before each operation.
At the same time, safety measures must be chosen that can be objectively verified and that do not depend on a complex individual assessment of each individual flight.
The generic operating authorization is therefore used mainly for repeated operations of similar type, for example during line construction inspections, mapping, technical inspections or similar assignments carried out at different locations under the same operating conditions.
A generic operating authorization is not an LUC license.
A generic operating authorization is sometimes confused with a license. LUC (Light UAS Operator Certificate), however, these are different institutes.
In the case of a generic operating authorisation, it provides operating conditions continue to be the relevant aviation authorityThe operator only verifies whether the planned operation complies with the already approved conditions.
The LUC license represents a higher level of organizational capability of the operator. An organization with an LUC license can, subject to compliance with legal conditions, approve certain changes to operations within the scope of the authorization granted by the aviation authority. It therefore requires an established safety management system, sophisticated internal processes and a higher level of organizational maturity.
It can therefore be said that a generic operating authorization brings greater operational flexibility, while an LUC license represents an even higher degree of independence for a professional operator.
záver
A generic operating authorisation is an interesting concept described in EASA's explanatory materials, which can significantly facilitate the implementation of repeated air operations in a specific category for professional operators. Instead of approving each individual location, it allows the use of one operating authorization for a wider range of similar operations, if all specified conditions are met. Generic operating however, the authorization is not a "freer" authorization, but on the contrary, it requires a higher degree of independence and responsibility of the operator.
For companies that regularly provide services using drones in various locations, it can represent significant savings in time and administrative costs.
In the next part of our series, we will focus on LUC license, which represents the highest level of organizational capability for professional drone operators and allows for an even greater degree of operational autonomy, subject to legal requirements.
Would you like to use a generic operating permit for your drone business? Do you need help with obtaining one? Contact us!
JUDr. Ing. Jan Vych, attorney and partner
