Autoritatea Aeronautică Civilă Romană

FREQUENTLY ASKED QUESTIONS (FAQ)

ERRATUM – Question No. 13

1.  What are the normative acts that should be complied with when using a UAS?

In order to use an unmanned aerial system (UAS) we must consider:

• European regulations applicable to this activity: Regulation (EU) No. 2019/945 "on unmanned aircraft systems and on third-country operators of unmanned aircraft systems" and Regulation (EU) No. 2019/947 "on the rules and procedures for the operation of unmanned aircraft ". All European civil aviation regulations contain AMC (Acceptable Means of Compliance) and GM (Guidance Materials); and
• National regulatory framework applicable to UAS: Law 21 on the Romanian Air Code and the Government Decision 912/2010 on flight authorization.

 

2. To which type of UAS are these regulations applicable?

The above-mentioned normative acts are applicable to all types of UAS.

We mention the fact that UAS refers both to the aircraft used and to the equipment through which it is controlled (command unit).

There are a variety of UAS, depending on their constructive characteristics (fixed wing, rotary wing, multirotor, balloon, etc.).

3. When is a UAS considered a toy?

An unmanned aircraft is considered a toy when it is intended for children up to 14 years of age and complies with the provisions of Directive 2009/48/EC. Compliance of an unmanned aerial system with the above mentioned Directive is based on the declaration of conformity issued by the manufacturer.

4. What does a UAS operator mean?

A UAS operator is a natural or legal person that operates or intends to operate one or more UAS. A UAS operator can also be the UAS pilot at the same time.

Example: A person who pilots a UAS for a company is the UAS pilot. The company is the UAS operator.

5. What is the difference between an autonomous UAS and an automatic UAS?

An autonomous UAS is an unmanned aircraft that performs the operation safely without any external intervention (e.g. pilot intervention). It is controlled by an artificial intelligence system, which handles all unforeseen or emergency situations.

In the case of an automatic UAS, all stages of the flight are predefined by the UAS pilot before the start of the operation.

 The use of automatic UAS is allowed in all categories of UAS operations, while stand-alone UAS are not accepted in the "open" category.

6. What does the phrase "uninvolved people" mean?

Uninvolved persons are persons who do not participate or are not involved in the UAS operation and do not know the instructions and procedures of the UAS operator. A person is involved if he/she decides to take part in UAS operations and knows the associated risks.

7. What does a crowd represent?

A crowd is a gathering of people who cannot disperse due to population density.

Examples of crowds:

• Sports, cultural, religious or political events;
• Crowded beaches or parks;
• Streets, street shops, etc;
• Resorts.

8. Can I fly over people?

Atunci când operați în categoria „deschise”, nu aveți voie să zburați deasupra persoanelor When operating in the "open" category, you are not allowed to fly over uninvolved persons, unless you have a privately built UAS weighing less than 250 g or one purchased on the market, with the CE mark and class 0 or 1 identification label. In any case, try to reduce as much as possible the time you fly over people. If you have a class C2 drone, and perform operations in subcategory A2, as a general rule, keep the UAS at a lateral distance not less than the flight altitude from any uninvolved person (this is "Rule 1:1", i.e. if the UAS flies at a height of 40 m, the distance from any uninvolved person should be at least 40 m) and should never fly closer than 30 meters horizontally, from any uninvolved person. If your drone is equipped with the low speed function and it is active, you can fly close to 5 meters from uninvolved people.

Distance from uninvolved people in the case of a class C2 drone flight

In all other cases (drones of class 3, 4, 5 or 6, or privately built and weighing more than 250 g), you must ensure that there are no uninvolved people in the operation area.

Art 4 (1)(c) and UAS.OPEN.040 of Reg. (EU) No. 2019/947

9. Do I still need to identify / register the unmanned aircraft?

A UAS is only registered if used for UAS operations in the certified category.

If the UAS operation is in the "open" category or the "specific" category, then the UAS operator must register and declare its aircraft. The registration of UAS operators can be done on the website: https://www.caa.ro/ro/pages/drone, where the online platform dedicated to this purpose can be accessed.

10. What happens after I register myself as an operator?

After registration, the UAS operator receives a unique registration code, which must be applied by a sticker on each UAS held. This unique code must also be entered in the remote identification system of the new UAS generations, which have a class C0-C6 label.

11. Is the operator registration recognized in Europe? 

    Please note that the operator registration can only be done in the state of residence of the operator, and the unique registration code is recognized by all Member States of the European Union.

12. How can I fly a model aircraft?

A person can fly a model aircraft:

• as a member of an aeromodelling club, association or federation, which has received an operating authorization from the Romanian CAA, in accordance with the provisions of Art. 16 of Regulation (EU) No. 2019/947. Such members must comply with the internal procedures and specifications stated in the authorization. The authorization shall specify the operating conditions in accordance with the provisions of Regulation (EU) No. 2019/947.
• as an unaffiliated person, complying with the provisions of Regulation (EU) No. 2019/947 for UAS operations in the “open” or “specific” category.

13. Can I operate a UAS in any area?

UAS operators shall verify the existence of any restrictions in the area of ​​operation. The restrictions in force at national level can be accessed on the Romanian CAA website in the "Drone" section https://www.caa.ro/ro/pages/drone.

The access of a UAS to a restricted area can only be done with the approval of the entity that imposed the restriction.

ERRATUM:

Operations in the "open" category may not be carried out in a restricted area.

Operations in the "open" category may be carried out in a restricted area if the limitations of this category are complied with and the following have been obtained in advance:

• approval of the entity that imposed the restriction;
• approval of the Ministry of National Defense for aerial filming / photography activities.

14. What is the minimum age from which a person can operate a UAS?

The minimum age for remote pilots in the "open" and "specific" categories is 16 years. For the flight of a drone with class 0 EC marking in subcategory A1, there is no minimum age.

Art 9 of Reg. (EU) UE No. 2019/947

15. Do I need to have a third-party insurance?

A UAS operator must have a third-party / liability insurance for an aircraft of which maximum take-off mass (MTOM) exceeds 20 kg.

16. How do I determine if the UAS operation is in the "open" category?

A UAS may be operated in the "open" category when: • it has one of the class identification labels 0, 1, 2, 3 or 4; or • it is privately built and weighs less than 25 kg; or • it is purchased before January 1, 2023, without a class identification label, • the operation is not carried out over persons, unless the aircraft has a class identification label or is lighter than 250 g. (Please refer to the subcategories of operations: A1, A2 and A3 to find out where you can fly with your drone) • the aircraft is kept in the visual line of sight (VLOS) or the remote pilot is assisted by a FPV (first person view flying) • flies at an altitude of maximum 120 meters, • does not carry dangerous goods and does not throw any material.

Art. 4, art. 5(1), Art. 20 and Part A of Reg. (EU) No. 2019/947, Parts from 1 to 5 of Annex to Reg. (EU) No. 2019/945.

17. In which subcategory of operations in the open category do I fall?

Subcategory	Class identification
A1 Outside urban areas or in urban areas but not above the crowds	0 or 1
	Privately built UAS with MTOM<25 kg Speed < 19 m/s
	UAS without class identification label with MTOM <250 grame including fuel and payload
A2 Distance from people of at least 5 m (or 30 meters depending on UAS characteristics)	Class identification 2
A3 Outside urban areas (150 meters from densely populated, residential, commercial or recreational areas)	Class identification 2, 3, 4
	Privately-built with MTOM < 25 kg Speed < 19 m/s

 

18. What are the operating requirements for each subcategory of UAS on which the class label has been attached?

Subcategory A1 - Class C0

 

Class C0 UAS can be operated in subcategory A1, but flights over the population must be limited.

 

Subcategory A1-Class C1

Class C1 UAS can be operated in subcategory A1, but flights over the population must be limited.

Subcategory A2

UAS with identification class C2 can be operated in subcategory A2. This means that they can be operated in urban areas, but UAS operations are carried out at a safe distance from any person not involved in the operation. As a rule, the minimum distance from persons not involved in the UAS operation is equal to the height at which the operation is performed (rule 1:1 - if the height is 30 m the distance from uninvolved persons is 30 meters).

Subcategory A3

UAS with identification classes C3, C4 or privately-built UAS having a MTOM of up to 25 kg may be operated in subcategory A3. They will not be operated in urban areas and they will be flown 150 meters from residential, commercial or industrial areas. UAS operations will not be performed over uninvolved persons.

19. What are the limitations of the open category for UAS without a class identification label (valid until 1 January 2023)?

UAS		Operation		Drone operator/pilot
Class	MTOM	Subcategory	Operational restrictions	Registration of drone operator	Remote pilot competency	Minimum age
Privately built	<250g	A1 (can also fly in subcategory A3)	-no UAS flight expected over uninvolved people (if this happens, time should be reduced); -UAS shall not fly over assemblies of people	No, unless the drone has  camera/sensor and it is not a toy	-no training needed	No minimum age
Drone without class identification	<500			Yes	-read user’s manual; -complete online training and pass online theoretical exam	16
Drone without class identification	<2kg	A2 (can also fly in subcategory A3)	- UAS shall not fly over assemblies of people -UAS keeps horizontal distance of  50 m from uninvolved people	Yes	- read user’s manual; - complete online training and pass online theoretical exam	16
Drone without class identification	<25kg	A3	-UAS shall not fly close to people; - UAS shall fly outside urban area (150 m distance)	Yes	- read user’s manual; - complete online training and pass online theoretical exam	16

 

Yes, you must have training appropriate to the category of drone you are about to operate. Training is not required if you use very light drones:

 

• if the drone bears the class C0 label, you only need to be familiar with the manufacturer's instructions; or
• if the drone weighs less than 250 g and is privately built (by you), you are not required to perform any training.

UAS.OPEN.020 of Reg. (EU) No. 2019/947

However, all other remote pilots must follow the necessary training. This means that, in the "open" category, all remote pilots flying in subcategories A1, A2 and A3, before the flight are required:

• be familiar with the manufacturer's manual;
• to take an online training offered by the Romanian CAA (please consult the website www.caa.ro); and
• to successfully complete an online theoretical exam (following online training).

The exam consists of 40 multiple-choice questions that assess theoretical knowledge.

After completing the above steps, AACR will issue a proof of completion of the online training that allows you to fly in subcategories A1 and A3.

UAS.OPEN.020 of Reg. (EU) No. 2019/947

If you intend to operate the UAS in subcategory A2, in addition to the above mentioned steps you should:

• complete practical training to familiarize yourself with your UAS and to ensure that you achieve a good level of control. This should be done in an area where you do not endanger the safety of other people, and
• take and pass an additional theoretical exam.

The test consists of 30 multiple-choice questions, which assess knowledge of ground risk mitigation, meteorology and flight performance. Upon completion, the Romanian CAA issues a remote pilot proficiency certificate for subcategory A2.

UAS.OPEN.030 of Reg. (EU) No. 2019/947  

21. As a remote pilot, do I have to record my flight time?

In order to be able to demonstrate your experience, you can record all your flights and flight times

CPD Procedure- Cpt. 1 art 1.5.

22. Who issues the certificate of competency of the remote pilot for the "open" category and for how long is it valid?

For the “open” category (and for the “specific” category based on standard scenarios), the Romanian CAA is responsible for issuing certificates of competency in Romania. A certificate for remote pilot is valid for 5 years. If the revalidation is carried out before the expiry of the certificate, the remote pilot may attend a seminar delivered by the Romanian CAA, otherwise the competency must be demonstrated again.

UAS.OPEN.070(1) of Reg. (EU) No. 2019/947.  

23. Will the certificate of competency for the "open" category be recognized throughout Europe?

Yes, the certificate of competency obtained in one EASA Member State will be recognized in all other EASA Member States.

24. Is it necessary to apply to the AACR for a permit to fly for the open category operations?

An UAS operator conducting "open" operations shall not require any authorization from the Romanian CAA.

As regards authorization of the flight activities, taking into account the mentioned above normative acts, the remote operator / pilot must comply with the following:

• 14 of Law 21/2020 on the Air Code regarding the establishment of the take-off / landing point in the case of flight activities involving UAS;
• 13, para. (3) of Law 21/2020 on the Air Code regarding the altitude regime;
• 15, para. (2) and (3) of Law 21/2020 on the Air Code regarding the prohibition of flying over densely populated areas / gatherings of people or objectives belonging to structures in the national defense system, public order or national security;

the authorization procedure detailed in the Government Decision No. 912/2010 (for “open” and “specific” flight activities).

25. Which are the responsibilities of a UAS operator in the "open" category?

A UAS operator operating in the "open" category must:

• ensure that its registration code (sticker) is visible on all his/her UAS and that the same code will be used for remote electronic identification;
• develop operating procedures (written procedures are mandatory when a UAS operator employs several UAS pilots. If there is only one pilot, then he/she must comply with the provisions of the manufacturer's manual);
• ensure that there is no radio interference that could disrupt the transmission of command and control to the UAS;
• to designate a UAS pilot for each operation; a person responsible for each operation must be designated;
• ensure that the UAS pilot and the persons involved in UAS operations know the operator's procedures, the manufacturer's manual (the UAS user manual), have the necessary skills and have complete information on the geographical areas;
• ensure that UAS maps are updated;
• ensure that the UAS has a declaration of conformity and has the identification class (C0 to C4) mentioned on the UAS or, in the case of a UAS without an identification class, comply with the operational limitations specific to this category of aircraft;
• ensure that persons involved in the operation are aware of the risks involved in operating in subcategories A2 and A3.

UAS.OPEN.050

26.   What are my responsibilities as a remote pilot in the "open" category?

As a remote pilot, you must:

• complete the necessary training and examination for the type of operation you want to perform;
• have relevant and up-to-date information about the published geographical areas (https://flightplan.romatsa.ro/init/drones);
• verify the existence of obstacles and the presence of uninvolved persons (unless you operate in subcategory A1 with a privately built drone having a mass of less than 250 g or with a drone with class identification label C0);
• check if the drone is suitable for the operation you will perform;
• check that the remote control works correctly (if applicable); and
• make sure that the maximum weight of the aircraft falls within the category or subcategory of the operation.

As a remote pilot, during the flight in the "open" category you must:

• do not use the drone when you are unfit due to the use of psychoactive / hallucinogenic substances or alcohol, or inappropriate due to the disease;
• keep the drone at such a distance that you can see it clearly. You can use a UAS FPV (first person view) to scan the airspace when performing “FPV” operations. UAS observers must be located next to you so that they can communicate immediately if they see an obstacle and give you instructions for landing;
• If you or the UAS observer see a manned aircraft on board, make sure you are away from it. If you have any doubts about the operation, you must land immediately;
• operate the drone in accordance with the manufacturer's user manual;
• follow the operator's procedure; and
• do not operate where an emergency response service is in place (for example, in the event of an accident, stay away from that location, as a HEMS helicopter may be required);

UAS.OPEN.060 of Reg. (EU) 2019/947

27.   If I fall under the "open" category, will I be able to fly my old drone after 31 December 2020?

Yes, from 31 December 2020 to 1 January 2023, you can operate the drone without a class identification label in the "open" category, under the following conditions:

• drones with a MTOM of less than 500 g cannot fly over people, and the pilot's competency is equivalent to that for subcategory A1;

• drones with a MTOM of less than 2 kg can fly at a minimum horizontal distance of 50 meters from people and the pilot must follow a training equivalent to that for subcategory A2;

• drones with an MTOM of less than 25 kg can fly in free areas, without people, 150 meters or more away from the property, and the pilot must follow a training equivalent to that for subcategory A3. However, after January 1, 2023, you can still operate the drone without class identification label:

• in subcategory A1 when the maximum take-off mass of the drone (MTOM) is less than 250 g; or

• in subcategory A3 when the maximum take-off mass of the drone is less than 25 kg.

Art 20, Part A of Reg. (EU) No. 2019/947 and Reg. (EU) No. 2019/945

 

28. How will the drone shows be organized?

Normally, drone shows will be organized by aeromodelling clubs, associations or federations. The UAS operations they conduct must comply with Art. 16 of Regulation (EU) No. 2019/947.

If a show will not be conducted by an aeromodelling club, association or federation, then it must be conducted in accordance with the limitations of the "open" category subcategory A3.

28. Can I carry out commercial activities in the "open" category?

Regulation (EU) No. 2019/947 does not provide for any restrictions on the conduct of commercial activities in this category of operations.

29. What does it mean to have operational procedures?

The UAS operator must have manuals / procedures to state how the flights are performed, the areas in which UAS operates, the existing risks for each operation (both for third parties and for the UAS or UAS operator). All persons involved in the operation of the UAS must know the procedures of the operator. The UAS pilot must comply with the operator's manual / procedures.

UAS.OPEN.050

30. How do I determine if the UAS operation falls under the "specific" category?

An UAS may perform UAS operations in the "specific" category if:

• it exceeds the limitations of the “open” category;
• The UAS operator wishes to conduct UAS operations in restricted geographical areas.

 

31. As a non-EU resident, are my "open" skills recognized in the EU?

Until 01.01.2023, the Romanian CAA will recognize:

 

• proof of completion of the online training (A1 / A3) and / or a certificate of competency of the remote pilot (A2) issued by a non-EU Member State;
• theoretical and practical training programs conducted in a non-EU Member State;
• theoretical examination and practical assessment, with a view to issuing proof of completion of the online training (A1 / A3) and / or a certificate of remote pilot competency (A2), carried out in a non-EU Member State, in the following conditions:

 

• if the non-EU authority requests such recognition from the Romanian CAA,
• proof of completion of the online training (A1/A3) and / or the certificate of remote pilot competency (A2) and all other documents attached to the application must be valid within the issuing State.

If you do not meet all of the above requirements, you will need to perform the necessary training before performing air operations with a drone.

Procedure-CPD Ch. 1 Art 1.13.  

32. Are all 'specific' remote pilots required to complete training to fly an unmanned aircraft?

For operations that fall under the "specific" category, the training depends on the intended operation. Unless the operation falls under a standard scenario, after the risk assessment, you will need to propose a training course/program to the Romanian CAA. The Authority will, in each case, assess the adequacy of the training and, if confirmed in the operational authorization, the training will become mandatory.

If your operation is in a standard scenario, the remote pilot must:

• hold a certificate of theoretical knowledge for operation in standard scenarios;
• hold an accreditation to complete practical training for STS-01 / STS-02.

To do this, the remote pilot must successfully complete and pass an online training course.

UAS.SPEC.050 (d) and UAS.SPEC.060 (b) of Reg. (EU) No. 2019/947.

33. Who issues the certificate of competency of the remote pilot for the "specific" category and for how long is it valid?

For standard scenarios, the Romanian CAA is responsible for issuing certificates in Romania. A certificate for remote pilot competency is valid for 5 years. If the revalidation is carried out before the expiry of the certificate, the remote pilot should attend a seminar delivered by the Romanian CAA or an entity recognized by it, otherwise the competency must be demonstrated again. For "specific" category operations not covered by standard scenarios, the training will be defined in the operational authorization issued by the Romanian CAA. 

Art 12 of Reg. (EU) No. 2019/947 and UAS.STS-01.020. 

34. Will the certificate of competency for the "specific" category be recognized throughout Europe?

Yes, the certificate of competency for the "specific" category obtained in one EASA State will be recognized in all other EASA Member States.

35.   What are my responsibilities as a remote pilot in the "specific" category?

As a remote pilot in the “specific”, before the flight you should:

• complete the necessary training and examination for the type of operation you want to perform;
• have up-to-date relevant information about geographical areas (https://flightplan.romatsa.ro/init/drones);
• verify the existence of obstacles and the presence of uninvolved people (unless it operates in subcategory A1 with a privately built drone or a CE class C0 drone);
• check if the drone is suitable for the flight and the intended operation;
• check that the remote control works correctly (if applicable); and
• make sure that the weight of the drone falls under the category or subcategory of the intended operation;
• ensure that the operating environment is compatible with authorized or declared limitations; and
• ensure that air traffic services, airspace users and other interested parties are informed of your intended operation.

As a remote pilot, during the UAS flight in the "specific" category, you should:

• not use the drone when you are unfit due to the use of psychoactive / hallucinogenic substances or alcohol, or inappropriate due to a disease;
• keep the drone at such a distance that you can see it clearly; you can use a UAS FPV (first person view) to scan the airspace when you want to fly with FPV. UAS FPV must be placed next to you so that they can communicate immediately if they see an obstacle and give you instructions on how to land the drone immediately;
• If you or the UAS FPV see a manned aircraft, make sure you are away from it. If you have any doubts about the operation, you must land the drone immediately;
• observe the limitation of geographical areas;
• operate the drone in accordance with the manufacturer's user manual;
• follow the operator's procedure; and
• do not operate where an emergency response service is in place (for example, in the event of an accident, stay away from that location, as a HEMS helicopter may be required);
• comply with authorized or declared limitations.

UAS.SPEC.060 of Reg. (EU) No. 2019/947

36. When conducting UAS operations in the "specific" category, do I need to have an authorization before each flight?

In the "specific" category, UAS operations may be performed:

• based on a standard scenario - the UAS operator submits a statement to the Romanian CAA, and the Romanian CAA transmits its confirmation;
• based on an operation authorization - the UAS operator submits manuals, procedures and risk assessments, according to Art. 11, and the Romanian CAA evaluates and, as appropriate, authorizes the operation. PDRA (predefined risk assessments) can be considered as procedures that a UAS operator can implement. These PDRAs are issued by EASA as amendments to Art. 11;
• based on a Light UAS Operator Certificate (LUC).

 

37. What are the responsibilities of a UAS operator in the "specific" category?

A UAS operator carrying out operations in the “specific” category must comply with the provisions of UAS.SPEC.050 of Reg. (EU) No. 2019/947.

38. What is a LUC (UAS Light Operator Certificate)?

A UAS operator - legal person may request the Romanian CAA to issue a LUC, as long as it can demonstrate that it is able to carry out its own risk assessments, develop manuals and approve them on its own. LUC is issued by the Romanian CAA, if the operator can demonstrate that it complies with all the provisions of Part C of Reg. (EU) No. 2019/947, and related AMC and GM, according to which the following privileges can be granted to the UAS operator:

• to perform UAS operations based on a standard scenario without submitting the operating declaration to the Romanian CAA;
• to issue its own authorization for UAS operations and to carry out PDRA specific UAS operations, without submitting to the Romanian CAA the application for the UAS operation authorization.

39. Do I need to hold a medical certificate to fly my drone?

Such a certificate is not required for UAS pilots operating in the "open" category. For the “specific” category, following the operational risk assessment, the medical certificate may be required (we recommend that you to refer to the responsibilities of the UAS pilot - question No. 25).

40. If I hold a Certificate of Identification issued by AACR for my drone, is it still necessary to register as an operator on the online platform? 

Considering the changes to the legal framework for the operation of unmanned aircraft after the European regulations for drones came into force, all UAS operators are required to register themselves on the online platform, where they will enter all the UAS they operate / intend to operate, whether they have previously been identified or not by the Romanian CAA.