Luna · ENAC question register

Ten questions. No answer claimed.

The completed, unsigned filing package asks ENAC to confirm the category, procedure, technical thresholds, operating boundaries, responsible offices, and repeatable path for Luna in Italy.

No PEC has been sent. No ENAC protocol number exists. ENAC has not replied. The questions below are a public, non-confidential synopsis of the draft and do not constitute an authorisation request for a specific operation.

Research stageFull-time research restart planned from 1 October 2026 · conditional

Communication record

Report verified. Signature and filing pending.

This status will change only against documentary evidence. Preparing a report is not sending it; sending is not protocol registration; protocol registration is not a favourable answer.

  • Report: single unsigned working report compiled and verified; the first official version starts only after CAdES .pdf.p7m signature
  • PEC: not sent
  • Protocol: absent
  • Authority response: absent
  • 2026 consultation: official comment form prepared and verified; ordinary email not sent; deadline 24 July 2026

Open regulatory questions

Context first. Then the point ENAC must close.

Each question starts from the rules already identified so that the authority can confirm, correct, or supplement the remaining point rather than repeat the public framework.

Read the source map
Q1

Legal classification

Given a non-propelled helium envelope continuously anchored to the ground, carrying no persons or goods and using remote functions only for lighting, telemetry, and safety, should Luna be classified as a non-passenger tethered gas balloon, a temporary obstacle, a mixed installation, or another category?

Q2

European and national perimeter

Where the final configuration satisfies Annex I point 2(a) of Regulation (EU) 2018/1139, and Article 1(2) of Regulation (EU) 2018/395 excludes tethered gas-balloon operations, which Italian provisions and ENAC procedure govern Luna?

Q3

National balloon-operation rules

Do ENAC's passenger tethered-balloon rules apply directly, partially, by analogy, or not at all to Luna? Separately, does the 6 November 2025 national air-operations regulation, which adopts Part-BOP for Annex I balloons, include an unmanned tethered lighting system and, if so, with which adaptations?

Q4

UAS treatment and remote functions

Does any UAS/RPAS product or operator provision apply despite the absence of propulsion and trajectory control? Do radio telemetry, dimming, shutdown, sensors, or controlled helium release alter the product classification, distinct from ATM-05B's procedural analogy for airspace use?

Q5

Technical thresholds and harmlessness

Which final-configuration values control the assessment: design volume, tether length, operating height, airborne solid mass, potentially falling mass, gas, cable, tethers, anchors, breakaway behaviour, or another criterion? Which evidence is required to support harmlessness?

Q6

Use cases, areas, and people

Which conditions apply to a private test, partner demonstration, controlled construction site, industrial area, private event, and public event? What separation, restricted volume, weather, height, and direct-overflight limits apply to involved workers and uninvolved persons?

Q7

ATM-05B, ATM-09A, and the 2026 transition

ATM-05B section 7.3 applies ATM-09 criteria and procedures by analogy to unmanned, non-powered tethered balloons and aerostats. Which height and distance limits, geographic-zone checks, forms, airspace reservation, ATS assessment, and NOTAM steps apply to Luna now? If the draft UAS Geographic Zones Regulation is adopted and repeals ATM-09A, which replacement or transitional rules will govern the ATM-05B analogy?

Q8

Light beam and eye-safety procedure

Does ATM-05B section 7.2 apply to Luna's diffuse downward LED emission as a light beam, or only to emissions capable of reaching or distracting aircrew? Which photometric, angular, shielding, glare, eye-safety, declaration, clearance, and informational NOTAM evidence is required?

Q9

Operator, documents, and insurance

Are certified personnel required, or can documented internal training be sufficient? Which operating manual, checks, maintenance records, weather limits, emergency procedure, safety case, technical tests, insurance, and incident reporting are required?

Q10

Obstacles, competent offices, and repeatable procedure

When does Article 709 require an obstacle assessment or authorisation, including outside airport safeguarding maps, and which ENAC office, ENAV/ATS body, airport or heliport operator, municipality, or other authority is competent? Can a model or test campaign receive a general technical assessment followed by site-specific checks, or is a separate filing required for every deployment?

Publication boundary

Public accountability without exposing the filing package.

What is public

The regulatory thesis, official source links, ten question themes, and evidence-backed communication status.

What is not public

Signed reports, PEC messages, delivery or acceptance receipts, protocol records, signatures, personal data, and confidential technical annexes.

How status will be updated

Only after the corresponding evidence exists: sent, delivered, protocolled, supplemented, answered, or closed. Silence will not be described as consent.

Operational stop rule

No deployment before the path is clear.

Until classification, competent procedure, site constraints, safety evidence, and required authorisations are established, Luna remains an R&D project and is not presented as available for public or commercial operation.

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