EU regulation 2020: do we all have to upgrade our Mavic Pro with Remote Identification Systems?

[swoermck]

Hi Mavic Pro owners,

reading through the upcoming EU rules, I'm a bit worried if we can still fly our old birds legally in 2020..

I just stumbled upon the classification of UAS in the directive 2019/945:

Delegated regulation - 2019/945 - EN - EUR-Lex

eur-lex.europa.eu

with less than 900g weight, I'd assume the old Mavic Pro will fall into the class 1:

A class C1 UAS shall comply with the following:

(1)

be made of materials and have performance and physical characteristics such as to ensure that in the event of an impact at terminal velocity with a human head, the energy transmitted to the human head is less than 80 J, or, as an alternative, shall have an MTOM of less than 900 g, including payload;

And further down I read:

(12)

have a direct remote identification that: (a) allows the upload of the UAS operator registration number in accordance with Article 14 of Implementing Regulation (EU) 2019/947 and exclusively following the process provided by the registration system; (b) ensures, in real time during the whole duration of the flight, the direct periodic broadcast from the UA using an open and documented transmission protocol, of the following data, in a way that they can be received directly by existing mobile devices within the broadcasting range: i the UAS operator registration number; ii the unique physical serial number of the UA compliant with standard ANSI/CTA-2063; iii the geographical position of the UA and its height above the surface or take-off point; iv the route course measured clockwise from true north and ground speed of the UA; and v the geographical position of the remote pilot or, if not available, the take-off point; (c) ensures that the user cannot modify the data mentioned under paragraph (b) points ii, iii, iv and v;

I think I read in this forum, that Ocusync is already broadcasting serial number and all other kind of data, but for sure it won't broadcast the "UAS operator registration number"?

Paragraph 12 (a) is pointing to regulation 2019/947:

Implementing regulation - 2019/947 - EN - EUR-Lex

eur-lex.europa.eu

and concerning article 14 we can read:

Article 14
Registration of UAS operators and certified UAS

3. The registration systems for unmanned aircraft whose design is subject to certification shall provide the fields for introducing and exchanging the following information:

(a)	manufacturer's name;

(b)	manufacturer's designation of the unmanned aircraft;

(c)	unmanned aircraft's serial number;

(d)	full name, address, email address and telephone number of the natural or legal person under whose name the unmanned aircraft is registered.

It says "..for unmanned aircraft whose design is subject to certification.." So does the Mavic Pro need to be registered? In other words: is the design of our bird "subject to certification"?

I'm a bit lost in all that law text, maybe someone can shade some light on this subject?

thanks,

Stefan