Light UAS operator Certificate (LUC)

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What is a LUC

The LUC is an optional operational certificate which, if obtained, guarantees some privileges to its holder. The highest privilege may be the possibility to start operations in the specific category without needing an operational authorisation by the NAA.  The availability of LUC certification represents a quantum change in the efficiency of drone aerial services, while ensuring safe conditions. Many working hours can be saved by speeding the process that otherwise would halt any work waiting for an authorisation to be formalised and approved.

National Aviation Authority evaluation of a LUC

An application for a LUC can only be sent to the NAA of registration. An UAS operator may decide voluntarily to ask its NAA to assess its organisation. This is to determine whether they are capable of evaluating the risk of their operations themselves. The requirements to be demonstrated by these operators are defined in Part C of Regulation (EU) 2019/947.  When the NAA is satisfied, they will grant, if necessary based on the organisation’s maturity, the privilege to the UAS operator to self-assess the risk of its operation and self-authorise it eventually, without the need for the NAA to do so (depending on the various degrees of privileges granted to that organisation under the LUC). It is recommended that, before granting a LUC, the NAA monitors the activity of the operator by issuing some operational authorisations and assessing the understanding of the operator of the regulatory framework, including SORA, and the level of its safety culture.

Regulatory reference: Article 5 of EU Regulation 2019/947.  

What are the LUC privileges?

The NAA may assign different privileges based on the maturity demonstrated by the operator. This may include the following, however different privileges may be defined:

  • To conduct operations covered by standard scenarios without submitting a declaration, or; 
  • To self-authorise operations conducted by the UAS operator and covered by a PDRA without applying for an authorisation, or;
  • To self-authorise all operations conducted by the UAS operator without applying for an authorisation.  

Of course, by fully complying with all the conditions set by the NAA and the applicable legislation.

A LUC is not…

It is not a “blank check” to do anything the organisation wants. The LUC holder can only conduct the operations described within the LUC terms of approval . This is why operating with a LUC certificate is both a great benefit and a responsibility.

Who can apply for a LUC?

Only operators with a legal entity are eligible to apply for a LUC. However, some of the activities contained in the manual can be subcontracted.

Regulatory reference: UAS.LUC.010.

LUC’s validity

The validity of a LUC is unlimited, as long as the organisation remains compliant with its LUC’s requirements. An organisation with a LUC can be subject to an oversight inspection by its competent NAA. A LUC can be revoked or surrender by the awarding NAA.

A LUC certificate is valid throughout the European Union.

Regulatory reference: UASE.LUC.080 of EU regulation 2019/947.

How will compliance with the drone’s technical requirements be verified by the organisation under the LUC?

The technical requirements applicable to the drone will be derived by the risk assessment and are independent from the fact that an organization may hold an LUC. They will depend on the specific assurance and integrity level (e.g. SAIL in SORA) of the operation, the technical mitigations applied (e.g. mitigation M2 in SORA) and the requirements on containment (e.g. step 9 of SORA).

Regulatory reference: article 12 of EU regulation 2012/947.

General requirements to obtain a LUC certificate

Operators must prove that they work in a structured way applying the basic elements of the safety management system, ensuring that flights are carried out safely, with control over planning, implementation, maintenance and back office administration. Criteria includes but are not limited to the following:

  • A safety management system to ensure that potential risks to aviation are effectively mitigated and managed;
  • Staff have the necessary remote pilot competencies along with planning, implementation, maintenance and administrative skills and competencies required for aspects such as daily operations, risk analysis and documentation;
  • Maintaining and managing a documentation system, keeping a log of relevant operating data accessible by the relevant NAA if necessary;
  • An operating LUC safety manual, covering a safety policy, objectives and including roles and responsibilities in the organisation concerning drone operations as well as where procedures and activities are documented, including emergency procedures.

For additional information please contact the team.

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