As part of the transition to the new European regulations for drones, Koninklijke NLR converted 1,219 professional drone pilots with an RPA-L or ROC-light to the European air ticket for Open Category A2 last year. NLR did so on behalf of the Ministry of Infrastructure and Water Management. The conversion had many feet in the Earth, but the majority of applications for conversion could be honoured.

Conversion Arrangement

On 31 December 2021, the Remote Controlled Aircraft Regulation (excluding State Operations) came to an end, and thus the validity of RPA-L certificates and ROC-light exemptions came to an end. To prevent drone pilots from getting to the ground literally and figuratively, the Ministry of Infrastructure and Water Management set up a transposition scheme. NLR was approached to implement this scheme.

The transposition proved to be quite a challenge: not only does European regulations have different flight powers, and therefore additional theoretical material was needed, NLR also had to check whether drone pilots had the right documents. At the end of July 2021, everything was in the process to implement the transposition. However, there was no complete and up-to-date register of individual drone pilots, so the initiative to start the conversion procedure was placed on the target group.

Drone flyers were able to sign up via a website specially created for this purpose. After completing a short refresher course and an additional theory module, the authority could be converted, provided that the applicant had a valid RPA-L certificate or the ROC-light decision issued by ILT with (due to new rules) also a ROC-light theory certificate. After that, the OPEN A2 drone proof could be requested free of charge from the RDW.

1,219 powers converted

A substantial part of the applications could not initially be approved. In addition to some incorrect and duplicate requests, eventually there were 486 applications that did not meet the conditions. These applicants received an email response explaining what was missing, after which part of them submitted an application again.

Of the total number of rejected applications, more than 400 did not meet the conditions for the conversion from ROC-light. In many cases, the “ROC-light Decision” was missing. A large group had not applied for these from the ILT after the exam. This resulted in a lot of disappointment, because it was not possible to transpose. Unfortunately, when transposing from RPA-L, it happened regularly that the certificate had expired. In some cases, the RPA-L certificate was missing and only the teacher’s certificate was added.

Ultimately, 1,219 privileges could be converted to OPEN A2. These pilots are registered with the RDW and have received login information from NLR to activate their authority.

Advantages and disadvantages of drone proof A2

According to NLR’s Martin Joosse, the flight ticket for Open Category A2 has the biggest advantage that one can now be active across the border without any doubt with drones. “For example, I spoke to a drone pilot from Limburg. Previously, it couldn’t be done in Germany or in Belgium. Now that’s no longer a problem.”

A disadvantage is that the drone ticket A2 represents less value than the RPA-L certificate. Notes such as RT (radio telephony), FI (flight instructor) or EVLOS (extended visual line of sight) could also not be included. Joosse: “Unfortunately, European regulations do not provide for a flight ticket similar to RPA-L. In the case of the Specific category, the operator must make it plausible that a kite is capable. This will go pretty well with some operators, but not all operators will have the resources to train their own pilots — let alone when it comes to one-man companies. So NLR would like to see flight tickets that are tailored to the Specific category. We are talking about this with the ILT, but this must ultimately also be coordinated at European level.”

Still rule-based

Although the new European regulations are basically risk-based, Joosse believes that the Open Category is very similar to the old rule-based system. “After all, you still have to deal with weight limits and hard distance requirements. In addition, it is not clear to everyone that, in addition to the provisions of the EU Regulation 2019/947, a number of Dutch rules have also been added, through the Unmanned Aircraft Regulations.”

Joosse also regrets that the new European rules are based on drones with Cx labels, but that there are still no drones with such a label. “As a result, you are a little limited as a drone pilot. Under the ROC-light you could fly with a 4 kg DJI Inspire, but that is not possible now in A2. And for that same reason, the European standard scenarios for the Specific category are not very good either, because they also assume drones with a Cx label.”