What is LUC? EASA Light UAS Certificate explained.

Executive Summary

The Light UAS Operator Certificate (LUC) is a voluntary operational certification under the European Union Aviation Safety Agency (EASA) framework. It allows unmanned aircraft system (UAS) operators in the Specific Category to gain significant operational privileges, including the ability to self-authorise certain operations without prior approval from their National Aviation Authority (NAA). This certification enhances operational efficiency while maintaining high safety standards, making it a valuable asset for mature UAS organisations.

Understanding the LUC

The LUC is part of EASA's regulatory framework under Regulation (EU) 2019/947, which governs European drone operations. It is designed for operators conducting higher-risk operations in the Specific Category. Unlike standard operational authorisations requiring NAA approval for each new activity, the LUC enables qualified operators to self-assess and authorise their operations within predefined limits and privileges.

Key Features of the LUC

Voluntary Certification: Operators are not mandated to obtain an LUC; it is optional for those seeking greater autonomy.
Privileges: Depending on the operator's maturity and compliance record, the NAA may include several privileges:
- Conducting operations under standard scenarios without submitting declarations.
- Self-authorising operations based on predefined risk assessments (PDRAs).
- Self-authorising all operations within the scope of their LUC approval.
Validity: The certificate is valid indefinitely across the EU, provided the operator complies with regulatory requirements.

Benefits of Holding LUC

Operational Efficiency:
- Eliminates delays associated with obtaining individual authorisations from the NAA.
- Reduces administrative workload for both operators and regulators.
Cost Savings:
- Streamlines processes, saving time and resources that would otherwise be spent on repeated applications.
Enhanced Autonomy:
- Operators gain control over their risk assessments and operational approvals, fostering a proactive safety culture.
EU-Wide Recognition:
- The LUC is valid across all EU member states, simplifying cross-border operations and operations in the Member States other than the State of registration.

How to Obtain LUC

Eligibility

Only legal entities can apply for an LUC. Individual operators are not eligible.
The organisation must demonstrate a structured approach to safety management and compliance with regulatory requirements.

Required Documentation

The operator must prepare an LUC manual. It is a combination of the Operations Manual and Safety Management System Manual, which can be combined or presented separately.

Application Process

Submission to NAA:
- Applications must be submitted to the NAA of the operator's country of registration.
Evaluation Criteria:
- Operators must prove they can effectively manage risks through a robust Safety Management System (SMS), qualified personnel, and comprehensive documentation systems.
Monitoring Period:
- Before granting full privileges, NAAs may monitor operators by issuing initial authorisations to assess their understanding of regulations and risk assessments like SORA (Specific Operations Risk Assessment).
Approval:
- Privileges are granted based on organisational maturity and compliance performance.

LUC Privileges Explained

The NAA may assign privileges in a phased manner depending on the operator's demonstrated capabilities:

without prior declaration to NAA, to authorise its operations based on an STS, and
without prior approval to NAA to authorise one or more of the following types of own operations:
- one based on a PDRA that requires an authorisation;
- one based on one or more modifications of an STS (variants), which does not involve changes in the ConOps, the category of UAS used or the competencies of the remote pilots; or
- one that does not correspond to a PDRA but falls within a type of activity already performed by the UAS operator.

In the case of UAS operations conducted at SAIL V and VI, the competent authority requires the LUC holder to use a UAS with an EASA TC. In the case of UAS operations conducted at SAIL III and IV, the competent authority specifies if the LUC holder is required to use a UAS with an EASA TC.

Responsibilities of LUC Holders

While the LUC provides significant benefits, it also comes with responsibilities:

Adherence to terms of approval outlined in the certificate.
Maintenance of a robust SMS to manage risks effectively.
Regular reporting and documentation are accessible for NAA oversight.
Ensuring personnel are adequately trained and competent for their roles.

Limitations of LUC

The LUC is not a "blank check" for unrestricted drone operations:

Operators can only conduct activities specified within their certificate's terms.
Non-compliance or safety violations can result in suspension or revocation of privileges.

Conclusion

The Light UAS Operator Certificate (LUC) represents a transformative step for European drone operators by balancing operational flexibility with rigorous safety oversight. Obtaining an LUC can be a strategic advantage for organisations aiming to scale their drone operations efficiently while maintaining compliance.

Actionable Recommendations:

Assess your organisation's readiness by evaluating your SMS, personnel qualifications, and documentation systems.
Engage with your NAA early to understand specific requirements and expectations.
Develop a robust compliance monitoring system to sustain the long-term validity of your LUC.
Reach out to Avtrain to discuss your next steps. We have worked with 3 UAS Operators to support and guide them in their LUC journey. Moreover, we continue to support two additional LUC holders with Regulatory consulting in their UAS operations.