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Cross-border operations

COURTESY TRANSLATION IN ENGLISH FOR EUROPEAN UNION OPERATORS COMING TO PORTUGAL

All approvals, including the proof of completion of online training, the certificate of competency in the Open Category or the confirmation of declarations and operational authorizations in the Specific Category operators are mutually recognized within the European Union.

Remote pilots of the Open Category can operate in another EU Member State with the same competency documents issued by the member state of registry in another member state. However, they must verify if specific legal regimes of that Member State are applicable, namely regarding the prohibitions or access restrictions in some geographical zones. Other legal rules that are not directly related to aviation may also apply, namely regarding sovereignty, privacy, insurance, environmental, and noise. Operators of unmanned aircraft that operate in the open category and intend to operate in another Member State are responsible for collecting the necessary information. As applicable, consult the website of the Competent Authority of the country of operation.

Authorizations of the Specific Category, issued by ANAC, are recognized in the other Member States of the European Union. The same is applicable with authorizations issued by other EU member states.

The operator submits to the Competent Authority of the Member State of operation the specific category authorization issued by its country of registry (CAA in the country were the operator is established) and the locations where it intends to carry out the operation, including local conditions assessment. The operator may start the operation as soon as he receives the confirmation from ANAC. If applicable, the authorization may need to be updated by the member state of the registry to include the new mitigations identified by the operator and accepted by ANAC.

For Portuguese Operators, ANAC will update this authorization after receiving information from the state of operation. ANAC may only participate in this process to update the authorization as requested by the Member State's counterpart Authority.

In cases where the operator intends to operate according to a standard declarative Operation Scenario, to which he already holds the confirmation of receipt and completeness issued by is member state of registry, he must submit to member state of operation (in Portugal ANAC), the declaration and a copy of the receipt and confirmation of completeness.

LUC Holders can carry out cross-border operations in any EU Member State without the need of issuance of a new LUC or operational authorization request. They only have to submit to the Competent Authority of that Member State the LUC issued by its member state of the registry and the locations (s) of operation were is possible to operate under the LUC privileges. ANAC will process the application request.

EASA published AMC/GM to article 13 to be used by the operators to apply for a cross border operations and achieve the conformity.


A. OPEN CATEGORY OPERATION IN PORTUGAL CONDUCTED BY OPERATORS REGISTERED IN ANOTHER EUROPEAN UNION MEMBER STATE

An open category UAS operator, registered in another Member State of the European Union, may operate in Portugal without authorization from the Portuguese Civil Aviation Authority (ANAC). To do so, you must comply with the rules of that open category and associated subcategories. If not complying with these rules and procedures, the operator cannot operate without holding a valid operational authorization, STS confirmation, or LUC issued by the member state of registry.

To operate in Portugal in the open category, the operator registered in another European Union country:

• You are registered as a UAS operator in a member state of the European Union, and you must attach your UAS operator number on the UA frame. If applicable, input registry number on the remote identification device and  comply with any airspace requirements (eg geographical areas);

• Operate a class labeled UAS according to open subcategory (A1, A2 or A3) conformity class marking requirement, or without during the transitional period and as per  allowed MTOM (250g, 500g, 2Kg or 25kg as applicable) for privately-build;

• According to the UAS type to be used (e.g. class label or without), comply with the rules and procedures for the open subcategory (A1, A2 or A3), as stated in Part A of the regulation;

• The remote pilot must hold proof of completion online training if conducting operations in open subcategories A1 or A3. A certificate of competence is required to operate in the A2 open-subcategory;

• The operator should verify the geographical areas published here (https://uas.anac.pt/explore), downloading these areas in the .kmz format to be used in the operations. The zones may be open in Google Earth for pre-flight verification. The operator must comply with the following:

OPEN CATEGORY PROHIBITIONS

- Do not operate in prohibited UAS operation areas established around international airports (red rectangles):

Humberto Delgado - Lisboa
Francisco Sá Carneiro – Porto
Faro – Faro
Cristiano Ronaldo – Ilha da Madeira
Porto Santo – Ilha de Porto Santo
João Paulo Segundo – Ilha de Ponta Delgada 
Santa Maria – Ilha de Santa Maria
Flores – Ilha das Flores
Horta – Ilha do Faial

Example: Humberto Delgado international airport prohibited area

https://uas.anac.pt/explore
Browser navigation map

1. Select geographical zone.
2. Information window is shown in the left side (“selected Advisories”) containing the requirement to comply.

Brief interpretation description: Prohibited to all UAS flights (e.g. open category) except if duly authorized/certified by a competent authority (through a cross border or under full certification).

 https://uas.anac.pt/explore  
 .kmz file 


1. Download the file .rar.
2. Open in google earth or import to your UAS system.
3. Select the geographical zone.
4. Information window is shown containing the requirement to comply.

Brief interpretation description: Prohibited to all UAS flights (e.g. open category) except if duly authorized/certified by a competent authority (through a cross border or under full certification).

   

 - Do not conduct Operations in prohibited established around police, customs and HEMS heliports (red circles)

https://uas.anac.pt/explore
Browser navigation map

1. Select geographical zone.
2. Information window is shown in the left side (“selected Advisories”) containing the requirement to comply.

Brief interpretation description: Prohibited to all UAS flights (e.g. open category) except if duly authorized/certified by a competent authority (through a cross border or under full certification).

 

https://uas.anac.pt/explore  
.kmz file 


1. Download the file .rar.
2. Open in google earth or import to your UAS system.
3. Select the geographical zone.
4. Information window is shown containing the requirement to comply.

Brief interpretation description: Prohibited to all UAS flights (e.g. open category) except if duly authorized/certified by a competent authority (through a cross border or under full certification).

 

 

 

- Do not operate in Humberto Delgado International Airport operational protection area 1 above 30m AGL or above the highest artificial or natural obstacle in a 75m radius centered in the UAS. Below that height you may operate (browser navigation map blue polygon left and right of the airport prohibited area / orange polygons in the .kmz file);

Example: Humberto Delgado International Airport operational protection Area 1

https://uas.anac.pt/explore
Browser navigation map

1. Select geographical zone.
2. Information window is shown in the left side (“selected Advisories”) containing the requirement to comply.

Brief interpretation description: Prohibited to all UAS flights (e.g. open category) above 30m AGL or above the highest obstacle in 75m radius centered in the UA, except if duly authorized/certified by a competent authority (through a cross border or under full certification).

 

 

https://uas.anac.pt/explore  
 .kmz file 


1. Download the file .rar.
2. Open in google earth or import to your UAS system.
3. Select the geographical zone.
4. Information window is shown containing the requirement to comply.

Brief interpretation description: Prohibited to all UAS flights (e.g. open category) above 30m AGL or above the highest obstacle in 75m radius centered in the UA, except if duly authorized/certified by a competent authority (through a cross border or under full certification).

   

 

- Do not operate in Humberto Delgado International Airport operational protection area 2 above 60m AGL or above the highest artificial or natural obstacle in a 75m radius centered in the UAS. Below that height you may operate (browser navigation map blue polygon left and right of the airport area 1 / yellow polygons in the .kmz file);

Example: Humberto Delgado International Airport operational protection Area 2

https://uas.anac.pt/explore
Browser navigation map

1. Select geographical zone.
2. Information window is shown in the left side (“selected Advisories”) containing the requirement to comply.

Brief interpretation description: Prohibited to all UAS flights (e.g. open category) above 60m AGL or above the highest obstacle in 75m radius centered in the UA, except if duly authorized/certified by a competent authority (through a cross border or under full certification).
 

https://uas.anac.pt/explore  
 .kmz file 


1. Download the file .rar.
2. Open in google earth or import to your UAS system.
3. Select the geographical zone.
4. Information window is shown containing the requirement to comply.

Brief interpretation description: Prohibited to all UAS flights (e.g. open category) above 60m AGL or above the highest obstacle in 75m radius centered in the UA, except if duly authorized/certified by a competent authority (through a cross border or under full certification).

   

- Do not operate in Humberto Delgado International Airport operational protection area 3 above 80m AGL or above the highest artificial or natural obstacle in a 75m radius centered in the UAS. Below that height you may operate (browser navigation map blue polygon north of airport area 2 / green polygons in the .kmz file); Example: Humberto Delgado International Airport operational protection Area 3


OPERATION IN THE OPEN CATEGORY RESTRICTED AND / OR SUBJECTED TO PRIOR APPROVAL (NO ANAC INVOLVEMENT)

In the following areas, operators can operate in the open category without the need for ANAC authorization, however, they require prior approval from the entity responsible for the zone or area:

- Autoridade Aeronáutica Nacional (AAN, www.aan.pt – Levantamentos aéreos/Aerial Surveys), In the areas where, for example, sovereign bodies and installations related to national defense and internal security are located, aiming to safeguard unlawful interference, prior approval is required to operate in zone 1, 2, 3 and 4 of Lisbon, the Naval Base of Alfeite (Oeiras), the São Julião da Barra Fortress (Oeiras) and the Iberlante Command (NATO). Due to internal security reasons, in any category and anywhere in the national territory, whenever the UAS has a sensor on board.

Applicable procedure: The remote operator must read the information available at https://www.aan.pt/subPagina-AAN-001.005.005-aeronaves-nao-tripulada-drones  to request administrative approval. It is strongly suggested prior coordination with contact AAN directly through imagens.aereas@aan.pt in case of doubts. The same applies if the operator intends to obtain an aerial survey approval. ANAC does not participate in this process.

 

https://uas.anac.pt/explore
Browser navigation map

1. Select geographical zone.
2. Information window is shown in the left side (“selected Advisories”) containing the requirement to comply.

Brief interpretation description: Prohibited to all UAS flights (e.g. open category) except if duly approved by AAN.

 

https://uas.anac.pt/explore  
 .kmz file 


1. Download the file .rar.
2. Open in google earth or import to your UAS system.
3. Select the geographical zone.
4. Information window is shown containing the requirement to comply.

Brief interpretation description: Prohibited to all UAS flights (e.g. open category) except if duly approved by AAN.

   

- Prior tactical approval of the Director of an aerodrome or heliport without a control zone (CTR) or traffic zone (ATZ) to fly above artificial or natural obstacles (contacts for coordination - Civil aerodromes: https://www.nav.pt/ais/vfr-manual/aerodromos ; ultra-light runways: https://www.nav.pt/ais/vfr-manual/pistas-ul, Civilian heliports: https://www.nav.pt/ais/vfr-manual/heliports)


a) If to operation is to be conducted in controlled airspace, the approval of the director is limited up to the maximum height defined in the airport operational protection area 1 (30m), 2 (60m), or 3 (80m);

b) Suppose the operation is to be executed in uncontrolled airspace (including in a Portuguese ATZ). In that case, the director may approve the open category operation above the height of the obstacles up to 120m above ground level.

Applicable procedure: The remote pilot must contact the aerodrome, heliport, or ultra-light runway director and request tactical approval to start the operation (use the airspace). The operator may share the contact details, the date, time, and duration of the operation. The aerodrome director reserves the right not to approve the operation if any negative safety impact is expected to manned aviation.


Example: Algés Heliport (Lisbon, establishes in area 2 of Humberto Delgado international Airport controlled airspace – if no heliport was established flight was possible in the open category up to 60m AGL)

 

https://uas.anac.pt/explore
Browser navigation map

1. Select geographical zone.
2. Information window is shown in the left side (“selected Advisories”) containing the requirement to comply.

Brief interpretation description: Tatical prior approval of the director required to operate UAS flights (e.g. open category) above the height of the nearest obstacle in a 75m radius centered in the UA up to 60m AGL (since in this example the heliport is in Humberto Delgado area 2)

 

https://uas.anac.pt/explore  
 .kmz file 


1. Download the file .rar.
2. Open in google earth or import to your UAS system.
3. Select the geographical zone.
4. Information window is shown containing the requirement to comply.

Brief interpretation description: Tatical prior approval of the director required to operate UAS flights (e.g. open category) above the height of the nearest obstacle ina 75m radius centered in the UA up to 60m AGL (since in this example the heliport is in Humberto Delgado area 2)

   

 
 

Example: Atouguia da Baleia Aerodrome (Peniche – Non-controlled airspace)

 

https://uas.anac.pt/explore
Browser navigation map

1. Select geographical zone.
2. Information window is shown in the left side (“selected Advisories”) containing the requirement to comply.

Brief interpretation description: Tatical prior approval of the director required to operate UAS flights (e.g. open category) above the height of the nearest obstacle in a 75m radius centered in the UA up to 120m AGL (since in this example the heliport is in non controlled airspace).

 

https://uas.anac.pt/explore  
 .kmz file 

1. Download the file .rar.
2. Open in google earth or import to your UAS system.
3. Select the geographical zone.
4. Information window is shown containing the requirement to comply.

Brief interpretation description: Tatical prior approval of the director required to operate UAS flights (e.g. open category) above the height of the nearest obstacle in a 75m radius centered in the UA up to 120m AGL (since in this example the aerodrome is in non controlled airspace)

   

 
Prior tactical approval of Aerodrome Director or AFIS service, in airfields with a traffic zone (ATZ), to fly above artificial or natural obstacles in a 75m radius centered in the UA up to 120m above the ground level (contacts for coordination - Civil aerodromes: https://www.nav.pt/ais/vfr-manual/aerodromos)

PORTUGAL MAINLAND
- ATZ de Bragança
-  ATZ de Chaves
- ATZ de Vila Real
- ATZ de Viseu
- ATZ de Coimbra
- ATZ de Castelo Branco
- ATZ de Ponte de Sor
- ATZ de Évora
- ATZ de Portimão

AZORES ISLANDS
- ATZ da Graciosa
- ATZ de São Jorge
- ATZ do Pico
- ATZ do Corvo

Applicable procedure: The remote pilot must contact the aerodrome director (administrative approval) or the AFIS service and request tactical approval prior commencing the operation (utilization of the airspace). The operator may share the contact details, the date, time, and duration of the operation in advance. The aerodrome director and the AFIS service reserves the right not to approve the operation if any negative safety impact is expected to manned aviation.

Example: Viseu Aerodrome (Viseu)

 

https://uas.anac.pt/explore
Browser navigation map

1. Select geographical zone.
2. Information window is shown in the left side (“selected Advisories”) containing the requirement to comply.

Brief interpretation description: Administrative prior approval of the director or Tatical approval of AFIS required to operate UAS flights (e.g. open category) above the height of the nearest obstacle in a 75m radius centered in the UA up to 120m AGL (since in this example an ATZ is established to protect the aerodrome and AFIS service is available)

 

https://uas.anac.pt/explore  
 .kmz file 


1. Download the file .rar.
2. Open in google earth or import to your UAS system.
3. Select the geographical zone.
4. Information window is shown containing the requirement to comply.

Brief interpretation description: Administrative prior approval of the director or Tatical aproval of AFIS required to operate UAS flights (e.g. open category) above the height of the nearest obstacle in a 75m radius centered in the UA up to 120m AGL (since in this example an ATZ is established to protect the aerodrome and AFIS service is available)

   

 

Others of environmental nature - Operation in parks and nature reserves:

Located in Portuguese mainland: The national plan for protected areas management is the responsibility of the Institute for the Conservation of Nature and Forests (ICNF I.P. - https://www.icnf.pt/ );

Madeira archipelago: Nature reserves and protected areas of Madeira islands are under the Institute of Forests and Nature Conservation (Regional Government) responsibility (IP-RAM - https://ifcn.madeira.gov.pt/servicos/formularios/licencas-autorizacoes.html);

In the Azores archipelago: Protected areas of the Azores network are under the Regional Directorate for the Environment of the Azores (Regional Government) responsibility (https://portal.azores.gov.pt/web/draac ).

 

Example: Parks and natural reserves managed by ICNF I.P.  – Sudoeste Alentejano e Costa Vicentina (Portugal Mainland. For Azores and Madeira check the .kmz and the browser)

 

https://uas.anac.pt/explore
Browser navigation map

1. Select geographical zone.
2. Information window is shown in the left side (“selected Advisories”) containing the requirement to comply.

Note: The geo maps are managed and provided by the institutes. 

 

https://uas.anac.pt/explore  
 .kmz file 


1. Download the file .rar.
2. Open in google earth or import to your UAS system.
3. Select the geographical zone.
4. Information window is shown containing the requirement to comply.

Note: The geo maps are managed and provided by the institutes.

   

Autoridade Aeronáutica Nacional (AAN, www.aan.pt – Levantamento aéreo/Aerial survey:

a) in military airspace  published in the AIP (Aeronautical information publication);

b) To mitigate internal security aspects, whenever a temporary prohibited zone is published due to military operations (https://www.aan.pt/subPagina-AAN-001.004.007-areas-temporariamente-proibidas ) through a navigation warning  (NOTAM) or in a AIP supplement.

Procedure to apply:

 
The operator shall request an administrative approval to AAN:

a) Verify first https://uas.anac.pt/explore  in order to assess if the operation will be conducted within a LP-R (restricted), LP-D (danger) or LP-P (prohibited area). If affirmative the operator shall read the contents available in https://www.aan.pt/subPagina-AAN-001.005.005-aeronaves-nao-tripuladas-drones  and request the said administrative prior approval. We strongly suggest contact directly AAN through imagens.aereas@aan.pt to obtain detailed information (i.e. including e-AAN webtool). The same procedure is applicable in case the operator intend to request an aerial survey. ANAC do not participate in this process.

b) Read the information available in  https://www.aan.pt/subPagina-AAN-001.004.007-areas-temporariamente-proibidas and the additional information published by AAN as regards to navigation warnings (NOTAM) or supplement related to military operations. If  a temporary prohibited areas is published by NOTAM for a given location (i.e., all operations prohibited, manned and unmanned) we strongly  suggest to contact AAN through imagens.aereas@aan.pt in order to check if it´s possible to submit an application in e-AAN and obtain the prior approval. ANAC do not participate in this process.


Example: Sintra Airbase LP-R42A

https://uas.anac.pt/explore
Browser navigation map

1. Select geographical zone.
2. Information window is shown in the left side (“selected Advisories”) containing the requirement to comply.

Brief interpretation description: Administrative prior approval of AAN required to start the operation (e.g. open category) up to 120m AGL.

 

https://uas.anac.pt/explore  
 .kmz file 


1. Download the file .rar.
2. Open in google earth or import to your UAS system.
3. Select the geographical zone.
4. Information window is shown containing the requirement to comply.

Brief interpretation description: Administrative prior approval of AAN required to start the operation (e.g. open category) up to 120m AGL.

   

 

Example: NOTAM A1714/21 – Temporary Prohibited area activated by AAN (military aviation authority) in Santuário de Fátima – Leiria

 AAN webpage informing active Temporary Prohibited Areas
https://www.aan.pt/subPagina-AAN-001.004.007-areas-temporariamente-proibidas

1. Enter in AAN webpage
2. Check the Temporary Prohibited areas table

AAN .kmz file if available in AAN webpage https://www.aan.pt/subPagina-AAN-001.004.007-areas-temporariamente-proibida

4. Download .kmz provided by AAN
5. Open the file on google earth to identify the location

 



3. If no .kmz file is not available:

a) use the coordinates available in “Descrição” (i.e. in this specific case for
A1714/21 is  39 37 53 N 008 40 23 W)


b) go to https://uas.anac.pt/explore and in the search field input the “local” name

(i.e.   input in the search as follows 

c) following icon will be available in the map view (i.e. )

d) Select the icon and move it until the coordinate information window

(i.e.   ) match the coordinates of

“Descrição” (i.e. )


e) NOTAM layered in the coordination location are available

 

 

B. CROSS BORDER OPERATION IN THE SPECIFIC CATEGORY – OPERATOR REGISTERED IN ANOTHER EUROPEAN STATE THAT INTEND TO OPERATE WITH HIS OPERATIONAL AUTHORIZATION IN PORTUGAL

An operator registered in another member state of the European Union that holds an operational authorization, a confirmation of receipt and completeness of an STS or a LUC, issued by its country of registry shall submit to ANAC an application as per article 13 of the Commission Implementing Regulation (EU) 2019/947 consolidated version.

Procedure to be applied: Submit an application according to article 13, providing the operational authorization, confirmation of receipt and completeness or a LUC, issued by the state of registry. Additionally, attach any necessary documentation to be assessed by ANAC. The package should be sent to drones@anac.pt. It is essential to include the operator's name, the UAS operator registry number, and the type of cross-border approval in the email subject field. The operator should include the updated mitigation measures, if needed, to address those risks identified under Article 11(2)(b) which are specific to the local airspace, terrain and population characteristics and the climatic conditions.

Considerations as regards to UAS operator assessment of local conditions:

To facilitate the calculation of the Airspace Risk Classification and aiming the application of the methodology to conduct the local assessment, holders of an operational authorization or LUC shall use the acceptable means of compliance and guidelines of the AMC1 of Article 11 of Commission Implementing Regulation (EU) 2019/947 (SORA methodology), taking into to account the following:


Local Airspace

Flights in the prohibited areas international airports and police, customs and HEMS heliports, including areas 1 and 2, above the maximum allowed heights in controlled airspace are considered as operations in airport environment “ OPS in Airport / Heliport environment ”;

Operations above the heights mentioned in area 3 of international airports operational protection areas up to a maximum height of 150m above the ground, is considered to be an operation in controlled airspace “Controlled airspace”;

Flights in ATZ / TRMZ that require authorization from ANAC, namely above 120 meters AGL, BVLOS , Swarms and over assemblies of persons, are assessed as “OPS in Mode C-veil or TMZ ”;

In all other circumstances, the operator must identify the ARC and apply the methodology explained in the SORA methodology to identify adequate mitigations to be submitted to ANAC.

Source:

Geo-zones: https://uas.anac.pt/explorer

Portugal Aeronautical information products: https://www.nav.pt/ais


Terrain

The operator must identify the terrain characteristics, including considerations as regards to the orography and artificial infrastructures canopy of the urban areas (skyscrapers, buildings, antennas, power line network), to identify adequate mitigations to be submitted to ANAC. The operator must take into consideration the effects of the terrain e.g. in the communication link stability, performance and continuity.

Source n.º 1:

http://mapas.dgterritorio.pt/

Official terrestrial datum:

Portuguese Mainland
PT-TM06/ETRS89 - European Terrestrial Reference System 1989

Madeira and azores::
PTRA08-UTM/ITRF93


Population characteristics

The operator may use the following sources to obtain population density information and appraise adequate mitigations to be submitted to ANAC. The operator must take into consideration the SORA GRC tables and the related ground risk mitigations as per population density.

Source n.º 1:

Qualitative:

Urban Centre Database UCDB R2019A (or the most updated source)

https://ghsl.jrc.ec.europa.eu/ucdb2018visual.php



Quantitative:

ENACT-POP R2020A (or the most updated source)

https://ghsl.jrc.ec.europa.eu/enactVisualisation.php

Source n.º2:

https://www.ine.pt/

Climatic Conditions:

The operator is responsible to identify and provide mitigations as deemed. Seasonal climatic changes based in historical data may be used to substantiate mitigations. Sources of certified weather information could be used. Due to wild fire season national regulations, the operator must duly introduce mitigations to cope with the escalonating effects of a fire caused by a UAS. The operator shall search from that info

Suggested Sources:

Weather information: https://www.ipma.pt/pt/index.html

Rural wildfires: http://www.prociv.pt/

The same local conditions detailed in “Operation in the open category restricted and/or subjected to prior approval (no ANAC involvement)” are applicable. The operator during is local conditions assessment (the location(s) of the intended operation including the updated mitigation measures, if needed, to address those risks identified under Article 11(2)(b) which are specific to the local airspace, terrain and population characteristics and the climatic conditions) prior the application of a cross border, shall provide supporting evidence that he have meet the local conditions requirements.

Holder of confirmation of receipt and completeness of an STS must operate complying with geographical zones requirements. Additionally, the flight geography shall be adequate to applicable STS provisions (STS-01 and STS-02). An application informing the locations is mandatory.

Insurance is regulated at national level and operators shall comply with National Portaria n.º 02/2021, Diário da República n.º 1/2021, Série I de 2021-01-04. You can check the Portaria in regulation webpage.