What is a Light UAS Operator Certificate (LUC)?
A Light UAS Operator Certificate or LUC is an organisational approval certificate for drone operators within the European Union. The certificate is issued by the relevant National Aviation Authority (NAA) to drone operators who have demonstrated the capability to effectively assess the risks of their operations themselves. This includes proving that they have the necessary expertise, internal processes, maturity and safety culture to self-authorise specific drone activities as per Part C of EU Regulation 2019/947.
What are the General Requirements for LUC?
As specified in Part C of EU Regulation 2019/947, a LUC holder is automatically considered to be a UAS operator and must be registered according to Article 14. LUC applications must also be submitted as a legal entity and cannot be submitted by an individual. According to EASA’s Easy Access Rules for Drones, the regulation also requires 3 main components when applying for a LUC:
The application itself requires standard information such as the applicant's name, address, place of business and intended operation date as well as 2 statements, the first to say that the document is the formal application for the LUC and the second to say that all information submitted has been verified by the applicant and it complies with the applicable requirements.
Before granting a LUC, the NAA typically monitors an operator’s activities by issuing initial operational authorisations to evaluate their understanding of the regulatory framework and safety measures, including adherence to Specific Operations Risk Assessment (SORA) methodology. The NAA may also perform an audit following the monitoring of the operator’s activities.
How Does SORA Support a LUC Application?
Specific Operations Risk Assessment or SORA, is an important step to achieving compliance for drone operations. SORA was developed by the Joint Authorities for Rulemaking on Unmanned Systems (JARUS) WG-6, who was led at the time by Murzilli Consulting’s CEO, Lorenzo Murzilli. During his time as part of EASA’s UAS Technical Body (TeB) and JARUS, Murzilli Consulting’s Director of Regulatory Affairs and Commercial Space, Juanjo Sola, collaborated on the development of SORA for the EU and its intermediate steps.
SORA’s methodology is a 10-step process that helps operators define their operation’s risk mitigations and safety objectives. An operator applying for an LUC needs to first complete a SORA to ensure a standardised evaluation of the risks associated with their intended operation.
It should be noted that the infographic above is based on the steps of the current EASA standard, SORA 2.0. SORA 2.5 was released by JARUS earlier this year and is intended to be implemented by EASA by the end of 2024, during which the SORA methodology steps will be adjusted accordingly.
What Does the LUC Documentation Look Like?
LUC Manual
A LUC applicant is required to provide the competent authority with a LUC manual which contains information describing the operator’s organisation, relevant procedures and the activities they intend to carry out. The LUC manual should contain key elements including a statement confirming that the organisation will work in accordance to the approved LUC manual and all of its conditions, how the LUC holder will handle external partnerships or activities, the intended plan for amendments and confirmation that the document will be distributed to all crew members. According to EASA’s Easy Access Rules, the format should be structured as shown:
Safety Management System
One key component of the LUC manual includes a safety management manual (SMM) outlining the intended Safety Management System (SMS) for drone operations using the LUC. The SMS should outline the organisation’s safety risk management procedure, roles and responsibilities and standards followed, personnel requirements, and safety policy.
Operations Manual
Another important part of the LUC manual is the operations manual (OM). This should include a detailed assessment of the ConOps, the normal, contingency and emergency procedures and the emergency response and incident report protocols.
Accident and Incident Management
This section is required to share the entity’s processes for handling, notifying and reporting accidents, incidents and occurrences. This includes the methods selected, who they are used by, whether or not it can be done anonymously and when it should be implemented.
Handling of Dangerous Goods
Applications must include a section on dangerous goods. The applicant must detail if they intend to carry dangerous goods, specify what they are, which crew members are involved in these operations, compliance with the relevant regulations and evidence of appropriate crew training for these operations.
What are the Privileges of a LUC Holder?
The process of obtaining a LUC often begins months before the certification is granted in what is known as a gradual approach. This entails the NAA assessing the operator’s activities, such as safety performance and records, which will help define the scope of the operator’s privileges.
Each LUC holder will have individualised privileges. Once the authority has assessed and is satisfied with the drone operator’s submitted documentation and evaluated the operator’s previously authorised performance, they will specify the terms and conditions of the operator's privilege, which (within the terms of its approval) should be:
To assess which STS or PDRA would be suitable for an operation, applicants can access the full list of standard scenarios (STS) and pre-defined risk assessments (PDRA) from the EASA website.
Why Should Drone Operators Consider a LUC?
While a LUC is an optional certificate, it has several operational advantages. Aside from the above-mentioned privileges, an LUC holder can accelerate an intended operation without needing to gain approval or authorisation for specific drone operations. This is an advantage for organisations that are using UAS on a regular basis, which can increase efficiency and reduce downtime for activities such as logistics, surveying and emergency services for operators possessing a LUC.
Another major benefit is that once granted, a LUC is valid across all EU member states. This means that a LUC holder, following the scope and privileges defined in their LUC, can operate within the EU without additional authorisation from local National Aviation Authorities (NAAs). However, it should be noted that operators may need to coordinate with local authorities on specific condition requirements, such as geographic or restricted areas, even with a valid LUC.
What Does a Valid LUC Contain?
A LUC includes several key elements that outline the operational parameters and
permissions for a UAS operator. These elements are:
With the LUC, the aircraft model may be left with some flexibility within the same initial GRC (ground risk class) column, provided that it is of the same type (multi-rotor, helicopter, VTOL, fixed-wing, etc.) as those already included in existing authorisations approved to the operator.
Responsibilities of a LUC Holder
Once obtained, operating with a LUC comes with a specific set of responsibilities that are defined within the LUC approval. These responsibilities include:
Record-keeping is a key responsibility for a LUC holder. The record-keeping system should be maintained and kept protected from damage, alteration and theft at all times. Records are also required to be available for the NAA upon request and must have a backup system established.
The LUC holder is also responsible for operational control. According to the EASA Easy Access Rules for UAS, “operational control should be understood as the responsibility for the initiation, continuation, termination or diversion of a flight in the interest of safety”. The Easy Access Rules also state that the LUC holder should include their organisation and methods to exercise operational control in the operation manual (OM).
How Drone Consultants Can Support a LUC Application
Applying for a LUC requires several factors, including regulatory compliance, risk assessment (SORA) and navigating the authority liaison. Using the services of a drone consultancy can help applicants by expertly creating a timeline for the process, highlighting any weaknesses in the documentation and increasing the success rate of the application due to their experience with the process itself. With these combined skills, applicants using a drone consulting firm will most likely be prepared for long-term compliance and will save time when applying for a LUC. Murzilli Consulting offers two services relevant to the LUC application:
SORA
Murzilli Consulting’s Operational Authorisations (SORA) and Third-Party Validation for SORA Mitigations and Operational Safety Objectives (OSOs) at High Robustness services can guide LUC applicants through the preliminary phase of their operation’s risk mitigations and safety objectives. This includes a 9-step systematic procedure that supports organisations from the initial assessment and ConOps to the final application phase, including complex SAIL III, IV, V and VI applications.
Light UAS Operator Certification (LUC)
Murzilli Consulting’s Light UAS Operation Certification (LUC) service offers end-to-end project management of the LUC application by providing support with the establishment, implementation, review, update and maintenance of a Safety Management System and LUC manual and any other relevant documentation. The service also includes aviation authority liaisons and support in responding to their feedback and questions.
The future of drone operations and its direction towards increased autonomy requires skilled operators who are committed to the industry’s development. The opportunity to obtain a LUC allows operators to achieve logistical advancements not only within their own organisations but also take steps toward the drone industry’s scalability and overall public acceptance.
Would you like to know more about our support services for LUC, SORA or any of our other customised services? Write to us for more information or to book an initial consultation.
