Camera drones and other unmanned aviation at Aalto University

In Finland, the use of camera drones and other unmanned aircraft is regulated by the Finnish Transport and Communications Agency TRAFICOM and new EU Drone Regulation.

The EU Drone Regulation (EU) 2019/947 entered into force on 31 December 2020, harmonising the rules and procedures for the operation of drones across the European Union. According to the regulation, all drone operators (both hobbyists and professionals) have to register and get trained as drone operators and, in most cases, pass an examination.

Aalto University Foundation is registered as a drone operator in the Finnish national register of drone operators as of August 2021. All drones must bear Aalto’s operator identification number for example on a sticker: FIN489661421686d

For those flying drones on behalf of Aalto University, you do not need to register as drone operator but you have to pass an examination (A1/A3 or/ and A2).

Regulations in aviation standards:

In addition to EU and other international provisions, Finland has adopted national legislation with which you have to comply, such as:

• Use of remotely piloted aircraft and model aircraft (OPS M1-32)
• Sections 2 (definitions), 9 (exceptions to the aviation regulations) and 11 (airspace restrictions), chapter 5 (need of commander, commander’s responsibilities, flight planning and execution), as well as sections 76 (use of flight locations and other areas), 136 (liability for damages) and 159 (activities endangering flight safety) of the aviation act (Ilmailulaki 864/2014)
• Government decree on areas where aviation is restricted (Valtioneuvoston asetus 930/2014 ilmailulta rajoitetuista alueista)
• Aviation insurance regulation (EC) No 785/2004
• Plant protection products act (Laki kasvinsuojeluaineista) 1563/2011; prohibition on aerial spraying
• Private life, sanctity of the home, data protection…
• General order and security
• Commercial rights management
• Noise, nature conservation and other environmental issues
• Defining priorities in situations where (Remotely Piloted Aircraft System, RPAS)
  • other activities are prevented due to RPAS activities
  • other activities prevent RPAS activities
  • operators engaged in simultaneous activity (also RPAS/RPAS) cause a hazard

Regulations outside aviation standards:

• Protection of privacy (Laki yksityisyyden suojasta työelämässä 759/2004)
• Sanctity of the home, section 10 of the Constitution of Finland (Suomen perustuslaki 731/1999)

For the purposes of Aalto, any aircraft referred to here falls under the definition of an ‘unmanned aircraft’. Regulations concerning model aircrafts are not applicable, as Aalto does not operate aircrafts for recreational or sports purposes.

Unmanned aircraft

An unmanned aircraft is an aircraft which is meant to be flown without a pilot on board (Traficom). Unmanned aircrafts are often equipped for certain functions, such as photographing or various measuring tasks. Remotely-piloted aircrafts are a subcategory of unmanned aircrafts. They are piloted by a remote pilot, or have the ability to allow intervention by a remote pilot at any stage of flight.

Model aircraft

Model aircraft are unmanned aircrafts that are used for recreational or sports purposes. Model aircraft can be either remotely piloted or autonomous, so-called free-flight model aircraft.

Consequently, no aircraft used in Aalto operations can be categorised as a model aircraft.

Accidents or near-miss situations

All accidents and near-miss situations involving remotely piloted aircraft have to be reported to the Finnish Transport and Communications Agency (Traficom) using this form: Flight safety report - Drone. Submitting a report will not lead to penalties. Instead, all reports will be processed for learning purposes, in line with the Just Culture principles observed in aviation.

Also report what happened to katja.paasikivi(at)aalto.fi.

A notification of all existing devices (drone) and all passed examinations (A1/A3 and A2) must be submitted to Emergency Preparedness Specialist Katja Paasikivi.

If you operate a drone, you (usually) need to pass a remote pilot examination, i.e. a theoretical knowledge examination online. 

Changes to registration for the A1/A3 online theoretical examination.

From 27.2.2024, the person must register himself for the online exam and this is a paid function (€30). Each schools/departments and/or units pays for this exam itself. The Finnish Transport and Communications Agency Traficom is renewing the functions and services related to the drone operator register during the spring. The change related to registration is part of this reform.

You can register for the exam via the "Theory exam without connection to operator" link. Registering for the online theoretical examination can be done electronically with strong identification. If you are unable to make a strong identification, registration takes place with a pdf form. Instructions for this can be found on Traficom's website droneinfo.fi.

If you register for the pilot test for a remote instructor, also send a message about it to katja.paasikivi(at)aalto.fi

Theoretical knowledge examinations in the open categories A1/A3:

If you are going to operate drones and your operations fall into the subcategories A1 or A3 of the Open Category of drone operations, you have to have sufficient knowledge of aviation safety, airspace restrictions, aviation regulation, human performance limitations and operational procedures. General knowledge of drones is also necessary.

• After Aalto’s drone operator has registered you for the theoretical knowledge examination online, you have a month to pass the exam. The number of times you can take the exam is not limited. You can take it as many times as you want within the period of one month until you pass it successfully.
• Familiarise yourself with self-study materials!
• Having passed the test, you will receive a proof of competency. It will be in force for five years, after which you have to retake the exam.
• However, if you pass another examination during the period of validity, such as the supervised additional theoretical knowledge examination (subcategory A2), your proof of competency will be valid for five year counted from your latest successful examination pass.

Theoretical knowledge examination in the subcategory A2 of the Open Category: If your drone operations fall into the subcategory A2, you may continue them until 31 December 2022 without taking the additional theoretical knowledge examination. The exemption will be extended from the previously issued deadline of 31 December 2021. The technical system developed for completing the A2 examination was implemented in late November.

To fly drones in sub-category A2, a remote pilot must, however, have a valid certificate granted for the completion of the A1 or A3 online theoretical knowledge examination and have completed the self-practical training required for participating in the A2 examination. 

The exemption only applies to flying drones in Finland. 

(After the exemption) If your drone-flying operations fall into the subcategory A2, you need to have sufficient knowledge of meteorology. In addition, you need further information on how to mitigate risks when flying near people and buildings.

• If you want to fly a drone with a take-off mass between 500 g and 2 kg in a densely populated area, you need to pass the theoretical knowledge examination for the subcategories A1/A3 online and then complete independent practical training. The requirements for and goals of independent practical training are described on the Droneinfo website. 
• After training, you will be able to take the theoretical knowledge examination for the subcategory A2. This exam is more traditional, as it is held in a classroom and supervised by the exam organiser. The fee for attending the remote pilot’s additional theoretical knowledge examination is 50 euros. The fee is paid by the department/school in question.

Further information about the categories of operation (open, specific and certified), the subcategories (A1, A2 and A3) and unmanned aircraft classes (C1, C2, C3 and C4) is available in the self-study material (Chapter 3: Aviation Regulations) and in the EU drone regulation information kit.

Remote pilots must be able to operate aircraft safely and be familiar with emergency procedures. The person responsible for a remotely piloted flight shall be at least 18 years of age.

The flight must be a visual line of sight operation (VLOS), i.e. a direct visual contact must be maintained with the remotely piloted aircraft at all times.

The flying height must be under 120 metres from the ground or water level.

Flying a remotely piloted aircraft over an open-air assembly of persons or over a densely populated area is only permitted under the conditions of the national Aviation Regulation OPS M1-32 (pdf, in Finnish).

• Maximum mass of the aircraft must not exceed seven (7) kilograms.
• The aircraft must be flown at such an altitude and equipped so that risks to outsiders and their property are minimal.
• The aircraft must be flown in direct visual contact.
• The operator of the remotely piloted aircraft shall have drawn up a written safety assessment for the specific operation.
• The operator shall have drawn up written operational instructions that include a description of both normal operations and emergency/malfunction procedures. Instructions for making operations manual and safety assessment can be found in “RPAS Operations Manual" (under the heading: "Additional requirements when flying above populated areas").

All drones must bear Aalto’s operator identification number for example on a sticker:  FIN489661421686d. In addition, add the name and contact information of the person responsible for the drone, on the drone.

Keep a log of all flights, containing all the required information. Any log format is acceptable as long as all necessary information is recorded and you keep the log for at least two years.

Note!

According to the terms of Aalto University’s insurance policy, the maximum take-off mass must not exceed 20 kilograms. This is an exemption to the general rule of 25 kilograms.

However, the take-off mass may not exceed seven kilograms, if the aircraft is operated over an open-air assembly of persons or over a densely populated area. In practice, all Aalto campus areas and the entire Capital Region are ‘densely populated areas’. 

You must familiarise yourself with the airspace at your disposal while planning your flight. Several restrictions apply to the use of airspace, possibly preventing you from flying as you please. These areas include the R (restricted) area, the P (prohibited) area where aviation is prohibited, areas where aerial photography is restricted specified in the Territorial Surveillance Act (755/2000), and the prohibiting and limiting UAS geographical zones. 

Areas where aviation is temporarily restricted or prohibited are for example visible in the Aviamaps Drone Map service. You can also use the service to submit notifications of your upcoming drone flights.

In Aalto Otaniemi campuses, there are no areas where flying an unmanned aircraft is restricted. Nevertheless, please note that occasional, temporary flight restrictions may occur. The temporary flight restrictions will be declared beforehand.

Exception to Aalto’s internal aviation restriction areas.

It is strictly prohibited to operate an unmanned aircraft in the premises of Metsähovi Radio Observatory (address: Metsähovintie 114, 02540 Kylmälä). An exception to this prohibition can be made in certain cases (for example, flights operated in research purposes). Only Metsähovi Radio Observatory can grant a permission to operate aircrafts in its premises. For further information and permissions, please contact Laboratory Engineer Juha Kallunki ([email protected]).

When operating an unmanned aircraft, the Government decree on areas where aviation is restricted (Valtioneuvoston asetus ilmailulta rajoitetuista alueista 930/2014) must be observed.

Do not encompass areas where aviation would be restricted. The closest prohibited areas are: EFP35 MEILAHTI, EFP40 MUNKKINIEMI and EFP50 KRUUNUNHAKA. Of the danger zones, especially EFD139A ARABIA (see D zones) must be observed.

Operating unmanned aircrafts such as camera drones as part of the core activities of the university is covered under the liability insurance policies. The insurance policy is similar to other Aalto University insurance policies, i.e. it includes a sizeable excess, but disasters are compensated for. Operators must understand that so-called strict liability is applied to the activity:

‘Strict liability, i.e. no-fault liability, from which there is no exclusion even by demonstrating that all measures were taken to avoid damages.’

In the Aalto insurance policy, there are certain special conditions imposed on aviation activities that must be met to ensure the validity of the insurance policy:

• The take-off mass of the aircraft, including load, equipment and fuel, must not exceed 20 kg
• The aircraft may not be jet-propelled
• The aircraft may not be used for recreational or sporting purposes: Aalto University’s insurance policy covers only teaching and research operations!
• The liability insurance of Aalto covers also Aalto University students when they are engaging in activities included in the curriculum while operating an aircraft.
• The flight must be a visual line-of-sight operation (VLOS).
• All written permits required for this activity have been acquired and are valid, and all the laws and decrees applicable to this activity have been complied with.
• The person engaging in aviation must meet the requirements concerning training and skills laid down in legislation and regulations.

Additional information (read before flight!)

Droneinfo