UAS geographical zones
The regulation is common to the whole Union, but what you are allowed to do depends on the ground you fly over. That paradox rests on one mechanism: the UAS geographical zone, defined by each State on its territory.
Key points
- Article 2(4) defines the UAS geographical zone as a portion of airspace that facilitates, restricts or excludes UAS operations. The first verb is the forgotten one: a zone is not necessarily a prohibition.
- The grounds go well beyond aviation safety: Article 15(1) names four: safety, security, privacy and the environment. The protection of personal data, for its part, appears a little higher up, in the definition in Article 2(4).
- A State may prohibit certain or all operations, request particular conditions, or require a prior flight authorisation (Art. 15(1)(a)). A zone that does not appear in red on a map may perfectly well be a conditional zone.
- It may also allow access to certain UAS classes only (point (c)), or only to aircraft equipped with certain technical features, such as remote identification or geo-awareness (point (d)). That is where the class label acquires operational value.
- Article 15(2) works the other way: on the basis of a risk assessment carried out by the competent authority, a State may designate zones where operations are exempt from one or more of the ‘open’ category requirements.
- Two actors, two verbs: the Member State DEFINES the zones (Art. 15), the competent authority MAKES AVAILABLE the information, in a common unique digital format (Art. 18(f)). It is that format which makes online consultation maps possible.
- On-board geo-awareness is not the zone: Article 2(15) makes it a function that detects a potential breach of airspace limitations and ALERTS the remote pilot. It informs, it does not block, and it is worth only as much as the data loaded by the operator (UAS.OPEN.050(5)).
The trap. Binary reasoning (‘allowed or forbidden’) makes you miss both ends of the mechanism. Flying in a conditional zone without meeting those conditions is a breach just as much as entering a prohibited one; and refusing an exempted zone on principle means missing a right the State has explicitly opened.
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Source
Implementing Regulation (EU) 2019/947 (CELEX 02019R0947, consolidated on 01/05/2025), art. 2, points 4) and 15), art. 15, paragraph 1 and paragraph 2, art. 18, point f), and Annex Part A, points UAS.OPEN.050(5) and UAS.OPEN.060(2)(c); AMC1 UAS.OPEN.050(4)(c) (ED Decision 2019/021/R)