Specific category flights

Based on the level of risk, there are three categories of operation of drones and other unmanned aircraft. Unmanned aircraft falls within the ‘specific’ category if one or more of the conditions for operation in the ‘open’ category are not met. To operate in the ‘specific’ category, authorisation from the Estonian Transport Administration is required.

‘Open’ category conditions, non-compliance with which implies the ‘specific’ category:

  • The unmanned aircraft is privately built and weighs less than 25 kg, or the unmanned aircraft bears the class C0, C1, C2, C3 or C4 identification label.
  • The unmanned aircraft was purchased before 1 January 2024 and does not have the above class identification label but weighs less than 25 kg.
  • The unmanned aircraft is not operated directly above people.
  • The unmanned aircraft is flown in accordance with the ‘open’ subcategory A1, A2 or A3 rules.
  • It is operated within visual line of sight (VLOS) or with the assistance of an unmanned aircraft observer.
  • It is not flown higher than 120 metres from the ground and/or water.
  • It does not carry dangerous goods or drop any material.

‘Specific’ category operations

To obtain specific cateory operational authorisation from Transport Administration, you need to send an application, operations manual and risk assessment conducted in compliance with European Commission regulation 2019/947 article 11. Also state fee of 250 euros must be paid for review of application. If application is correctly formed, state fee is paid, then Transport Administration will make decision to grant or not to grant operational authorisation within 90 days. Transport Administration inspectors use EASA guidance material to validate documents sent by applicant.

There are several ways of obtaining the right to operate in the ‘specific’ category.

  1. operational declaration – STS (Standard Scenarios);
  2. operational authorisation – PDRA (Pre-Defined Risk Assessment);
  3. operational authorisation – SORA (Specific Operations Risk Assessment);
  4. light UAS operator certificate (LUC).

‘Specific’ category operational authorisations issued in Estonia are also valid in other EASA member states as long as national requirements are met. You should contact the competent authorities in the relevant country to find out which documents need to be submitted in that country.

All options have different documents needed. More information can be found in the table below or via links below.

Cross border operations in specific category

When you have obtained operational authorisation from Estonia, you can use same documents to fly in other EASA member states. You need to contact local authority to get more information about local conditions.

If non-Estonian specific category operator wants to operate in Estonia, they need to send an application, copy of operational authorisation given to them at their home country and document with information about planned locations in Estonia and additional risk mitigation measures if that is needed. After application is sent, then Transport Administration assesses the documents and after operator has received confirmation, they can start their operations.

Drooon

When flying under an operational declaration, the risk assessment is based on a standard scenario (STS). STS is one of the ways to operate a flight in the ‘specific’ category. All STSs define a specific scenario that can happen when flying an unmanned aircraft. There are currently two STS scenarios created by EASA: STS-01 and STS-02. The scenarios also list the general conditions that an operator must follow to ensure a legal and safe flight. This is the easiest way to operate in the ‘specific’ category, as the STS already includes a risk assessment, but you need to have C5 or C6 class marked unmanned aircraft to use this option. When you declare STS operations you need to familiarize yourself with European Commission implementing regulation 2019/947 annexes and make operations manual according to annex 5.

Basis The applicant can operate according to the situation (scenario) defined by EASA. By submitting a declaration, the operator confirms their compliance with the conditions set out in the STS.
Risk assessment Passed
Class label C5 or C6
Period of validity Maximum 5 years
Area of validity Estonia and Europe (on the basis of a cross-border operation request)
Pilots Completion of theoretical and practical examinations according to the STS class used
Cost The review is subject to a state fee of 150 euros.
Processing time The time limit for the review of an operational declaration is 30 days, which can be extended by a further 30 days.

STS 01

Visual line of sight Yes
Area Controlled ground area also over populated area
Airspace Controlled or not controlled
Height Maximum 120 metres
Unmanned aircraft Up to 3 metres in diameter
Class label C5
Pilot Completion of theoretical and practical examinations according to the STS class used

STS02

Visual line of sight Yes, EVLOS is possible
Area Controlled ground area over sparsely populated area;
Airspace Controlled or not controlled
Height Maximum 120 metres
Unmanned aircraft Up to 3 metres in diameter
Class label C6
Pilot Completion of theoretical and practical examinations according to the STS class used

An operational authorisation can be based on a PDRA (Predefined Risk Assessment). The PDRA tables are designed to facilitate applying for an operational authorisation and allow the operator to use a risk assessment already carried out when compiling the PDRA tables. PDRA is designed to allow more complex operations compared to STS and has been developed by the European Aviation Safety Agency (EASA) using conventional unmanned aircraft operations as an example of what can happen and how to avoid potential accidents and ensure safety.

To use the PDRA tables to apply for an operational authorisation, the operator must demonstrate that their activities meet all the requirements and conditions set out in the PDRA tables. While STS has a class label (C5-C6) on the unmanned aircraft, PDRA does not pose such a requirement. PDRA S01 and S02 use the same risk assessment table as the corresponding STS. PDRA, unlike STS, does not impose one specific method of operation but gives the operator more freedom to choose their operations.

is in reality a sort of checklist on how to develop the procedures that needs to be contained in the operator manual.

PDRA tables are available here:

PDRA classes

Two types of PDRA are distinguished: PDRA-S and PDRA-G. The former corresponds to the STS but allows the use of unmanned aircraft without a class label. The latter, however, includes risk assessments for the operation of other specific types of unmanned aircraft, which are more common in Europe.

More information about Predefined Risk Assessment (PDRA) 

SORA (Specific Operations Risk Assessment) is a specific risk assessment, which is carried out by methodically identifying the risks associated with the planned operation of an unmanned aircraft. For all flights that do not fall under STS or PDRA, a risk assessment in accordance with the SORA principles must be submitted to apply for an operational authorisation.
 

When must the SORA principles be followed when applying for an operational authorisation?

Although the STS and PDRA are also based on the SORA principles, they do not cover all flights. The operator must therefore carry out the SORA risk assessment procedure independently. This method is used for risk assessment when operations are more complex than in PDRA.

Briefly about SORA

The SORA method is a process in which the risks of complex operations are systematically assessed and potential vulnerabilities identified. Applicants determine in ten steps where, when and how they will carry out their operations without harming people or objects in the air or on the ground. The process should result in a detailed description of the planned operation and the associated risks as well as the means and activities to mitigate these risks.

The ten steps of SORA

Knowledge

What knowledge is needed for SORA? The risk assessment is carried out by the applicant (i.e. an institution or person wishing to carry out complex ‘specific’ category operations). Knowledge of aviation, as well as of conventional security-related systems in aviation, is essential. Depending on the complexity of the planned operation, the SORA method is a sophisticated process to follow, particularly where risk assessment is not a regular part of the applicant’s activities.

Support

If the applicant organisation is not competent to carry out a risk assessment, it can use the guidance material developed by EASA, which describes precisely how the SORA documentation should be completed. There are also companies that offer consultancy services for SORA applications.

Steps to obtain an operational authorisation

SORA application can be time-consuming. Conducting a risk assessment is a lengthy process, and so is the review of the application by the Estonian Transport Administration and, if necessary, giving feedback. It should therefore be taken into account that obtaining an operational authorisation can take a very long time.

What to consider when filing a SORA application?

Time. The applicant carries out a risk assessment and prepares the documents to be used for the operations. In addition, the operations require approval by the Estonian Transport Administration. Due to the volume of data that both the preparer and the reviewer have to handle, please allow several months for the preparation and validation of the SORA risk assessment.

Flexibility. The SORA method is carried out by the operator. Therefore, the operations must later comply with the assessment. It is up to the applicant to choose how extensive the risk assessment is and, therefore, how much freedom they will have in future operations. There is no need for a class-labelled unmanned aircraft, while insurance is required.

Complexity. For SORA risk assessment, the planned operations are assumed to be complex or highly complex. That is because the risk assessment does not cover pre-defined general common operations (for example, as exemplified in the PDRA tables). Depending on the complexity of the planned operations (SAIL 1 to 6), the requirements are more demanding and also require some basic knowledge of aviation.

Cost. The cost of the SORA assessment and review depends on the complexity of the planned operations and the quality of the documents originally submitted. Only fee that is fixed is state fee, but applicant will have more costs because of developing the needed documents. It is therefore difficult to set a fixed price.

The EU Regulation on unmanned aircraft has provided a new possibility for granting operational authorisations. The light UAS operator certificate or LUC is intended for light unmanned aircraft systems. LUC holders can confirm their flights themselves, i.e. they do not need to be authorised or approved by the Estonian Transport Administration. LUC holders must meet specific conditions, which are stricter than for ordinary operators. LUC requires a higher level of aviation knowledge and is intended for professional operators who regularly fly in similar conditions.

The conditions for obtaining an LUC are set out in Part C of the Annex to the European Commission Implementing Regulation (EU) 2019/947.

Flights where the risks are much higher than those in the ‘open’ or ‘specific’ categories fall within the ‘certified’ category. In addition to other stricter requirements, aircraft certification is required here. Examples of flights that fall under the ‘certified’ category include:

  • flights over people;
  • the transport of people;
  • the carriage of dangerous goods that may pose a danger for third parties.

The ‘certified’ category requirements are under development by the EASA and Member States. Therefore currently authorisations for this category cannot be applied.

 Which path to choose to obtain authorisation for ‘specific’ category operations?

The first step is to identify the needs and purpose of the planned operation and choose the appropriate approach accordingly. This will help to submit the correct applications and obtain an appropriate operational authorisation that covers the content of the planned operations.

To apply for an operational authorisation in the ‘specific’ category, send an application to the Estonian Transport Authorisation at info@transpordiamet.ee. The application must be accompanied by an operations manual and documents proving compliance with the operating requirements. These include, for example, SORA risk assessment or PDRA compliance assessment tables and any other documents that demonstrate compliance with the security requirements resulting from the risk assessment.

The application form for an operational authorisation can be found on the forms page.

The review of an application for an operational authorisation is subject to a state fee.

For more detailed conditions on all requirements, see the European Aviation Safety Agency (EASA) website.

OPERATOR
TYPES OF OPERATIONAL AUTHORISATION
Kronja OÜ  PDRA-S01
Meridein OÜ  PDRA-S01
Threod Systems OÜ SORA (SAIL II)
OÜ TipsTops PDRA-S01
Hepta Group Airborne OÜ PDRA-S01, PDRA-S02, PDRA-G01, PDRA-G03, SORA
Estonian Aviation Academy PDRA-S01, PDRA-S02, PDRA-G01
Enersense AS  PDRA-G03

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Last updated: 11.12.2024

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