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EASA Decision on PDRA S-01

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In late October 2023, EASA (European Union Aviation Safety Agency) published a new version of the AMC (Acceptable Means of Compliance) and GM (Guidance Material) that affect Regulations (EU) 2019/945 and 2019/947.

In this article, we will analyze some of the key changes in this new Decision 2023/012/R published by EASA. 

Changes in Requirements for Drone Operations using SORA

Let’s remember that when conducting a risk analysis using the SORA methodology, based on the obtained value, the requirements need to be justified in a simpler or more complex manner. One of the requirements concerns the design of the aircraft, and in the initial stages, it had to be demonstrated as safe through the issuance of a type certificate (TC) or a restricted type certificate (RTC), just like for manned aircraft.

These certificates were considered disproportionate, so EASA created a more proportionate option for UAS (Unmanned Aircraft Systems): the Design Verification Report (DVR).

The DVR was only required when the risk of operations was considered medium, resulting in a SAIL III and IV outcome, with TC and RTC being reserved for high-risk operations.

After 2 years of drone flights in Europe and thousands of flights conducted without significant accident records, the DVR will only be necessary for operations with a SAIL IV value. For values lower than SAIL IV, the competent authorities of each EU member state may accept the operator’s declarations and, if deemed necessary, request additional evidence.

Adaptation of PDRA S-01 for Agricultural Drones

PDRA S-01 is the equivalent of the standard scenario STS-01, with the difference that it is not necessary to use a drone with a C5 class label. With the applied changes, this scenario will also be the basis for flights for the application of phytosanitary products in agriculture.

The modifications that have been made include:


  • The 25 kg limit for the UAS has been removed (while maintaining the maximum dimension of 3 meters).

  • Compliance with Directive 2009/128/EC.

  • Proper definition of the locations where the operations will take place.

  • Addition of operations at a maximum altitude of 10 meters.

  • The need to define procedures for flying in controlled airspace.

  • No requirement to use an enhanced containment system if the flight is conducted in areas where the adjacent area is considered low risk.