Member Article

Confusion with EASA 945 & 947 Transitional Arrangements

Author - Jamie  Sayer, Principal Safety Engineer & UAV Expert at Ebeni Ltd


Introduction


There has been some confusion with the 945/947 Official Rules Adoption and the Transitional Arrangements. I'm still confused plenty of times and I've read it many times over! Even the AAIB didn't quite get it right in their Jan 2020 bulletin. So here goes my attempt to explain it....... Firstly, please be mindful that there is a new opinion out, which will now introduce a 5th and 6th class of UAS.

Exemptions - 947, Article 20, until 1 July 2022

Drones can continue to operate , where they have been placed on the market prior to 1 Jul 2022 in the following categories: "In subcat A1 - provided it weighs less than 250g (i.e, C0). does not overfly assemblies of people and reasonably expects no uninvolved person will be overflown.

In subcat A3 - provided it weighs less that 25kg (i.e, C3), operations are conducted in an area where the RP reasonably expects that no uninvolved person will be endangered within the range where the unmanned a/c is flown, operations are conducted at a safe horizontal distance of at least 150m from residential, commercial, industrial or recreational areas, operations are performed by a RP who has completed an online training course and passed an online theoretical knowledge exam as defined in UAS.OPEN.020, or: Is marked as Class C2 (rather defeats the object of the exemption) and complies with the requirements of that Class, or: is marked as Class C3 (rather defeats the object of the exemption) and complies with the requirements of that Class.

Transitional Arrangements 947 Article 22 Until 1 July 2022

Less than 500g so long as: Does not overfly assemblies of people and reasonably expects no uninvolved person will be overflown." "Less than 2kg so long as: Keeping a horizontal distance of 50m from people and the RP has a competency level at least equivalent to the one set out in UAS.OPEN.030(2).



Between 2kg and 25kg so long as: Operated within the op requirements set out in UAS.OPEN.040(1) and (2): operations are conducted in an area where the RP reasonably expects that no uninvolved person will be endangered within the range where the unmanned a/c is flown. Operations are conducted at a safe horizontal distance of at least 150m from residential, commercial, industrial or recreational areas RP competency level to UAS.OPEN.020(4)(b)

Confusion with EASA 945 & 947 Transitional Arrangements

The bottom line is that if you are a drone operator who wants to do anything more slightly complicated than fly in benign areas away from people and buildings, you will want to invest in EU 'Conformed' products asap. Otherwise you will find yourself having to park your drones for something compliant. This may be okay if you only expect your drone to last a few months anyway. Also, if you aspire to eventually conduct BVLOS operations, then you would want a flexible product which meets EASA 945, whilst has the resilience and reliability to achieve 'Specific' permissions.

It is my understanding that some of the larger designers will have conformed products on the market early next year, so you may want to carefully approach your investment decisions

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