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Luna regulatory map

Compliance before operation.

This public map separates official rules, our provisional reading, and the questions that only the competent authorities can close for a non-passenger tethered helium lighting system.

Luna is in research and development. No operational deployment, airspace test, or public demonstration has been authorised. Nothing on this page is an approval, certification, or substitute for a site-specific assessment.

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

Current public status

A legal hypothesis, not operating permission.

The final legal position depends on verified product parameters, the intended site and use case, and written direction from the competent authority.

  • Research and design work may continue within controlled, non-operational boundaries.
  • No physical deployment is presented as lawful merely because the concept is small, tethered, or intended to be harmless.
  • Classification, procedure, operating limits, documentation, insurance, and authority coordination remain open.
  • Official sources and written authority responses prevail over this explanatory page.

Provisional legal reading

The European rules define the edge; Italy must define the path.

The layers below are read together. None is used alone to claim that Luna may operate.

01

Conditional Annex I perimeter

Annex I point 2(a) of Regulation (EU) 2018/1139 places a non-propelled tethered aircraft outside the common EU regime only when the tether is no longer than 50 m and either MTOM is below 25 kg or, for lighter-than-air aircraft, maximum design volume is below 40 m³. Final Luna values must be verified before relying on that perimeter.

02

Express 2018/395 exclusion

Article 1(2) of Regulation (EU) 2018/395 says that the regulation does not apply to air operations with tethered gas balloons. This exclusion points to national treatment; it does not itself create permission to operate.

03

National gap for a non-passenger product

ENAC states that tethered gas balloons remain nationally regulated, but the national rules it expressly links concern balloons intended to carry persons. Luna is tethered and gas-filled but does not carry persons, goods, or a pilot. Direct, partial, or analogical application therefore remains for ENAC to determine.

04

Obstacle rules remain site-specific

Article 709 of the Italian Navigation Code may matter if a fixed or mobile object interferes with protected surfaces. ENAC also directs applicants to airport safeguarding maps, municipal technical offices, and central compatibility assessment depending on geography. Luna is not automatically declared an obstacle on this page.

05

The 2025 national operation framework

ENAC's National Air-Operations Requirements of 6 November 2025 adopt Part-BOP as the national rule for non-commercial and commercial operations with Annex I balloons. The text is important, but it does not remove the need to ask whether an unmanned tethered lighting system falls within that use of “balloon” and which crew-oriented provisions can apply.

06

ATM-05B creates an express airspace bridge

ATM-05B sections 5.1(g) and 7.3 expressly cover unmanned, non-powered tethered balloons and aerostats. For airspace use, the circular treats their operations as analogous to drones and applies ATM-09 criteria and procedures. This procedural analogy does not by itself reclassify Luna's product as a drone.

07

Light emissions and a live 2026 transition

ATM-05B section 7.2 separately requires an eye-safety declaration and a territorial clearance/NOTAM path for laser or light-beam activity. In parallel, ENAC's draft UAS Geographic Zones Regulation, under consultation until 24 July 2026, would repeal ATM-09A if adopted. Its future effect on the ATM-05B analogy is therefore an open, time-sensitive point.

08

Liguria creates a separate lighting constraint

Liguria Regional Regulation 5/2009 expressly addresses luminous aerostatic balloons that scatter light towards the sky when used for advertising or recreational attraction, even temporarily. A functional, shielded, downward-lighting design may be materially different, but that distinction must be confirmed with the Region and municipality before any local use.

09

Aviation is only one compliance layer

Final radio, electrical, EMC, pressure-equipment, helium-transport, workplace, event, fire-safety, environmental, and insurance requirements depend on configuration and site. ENAC is asked to define the aviation interface, not to replace the product, workplace, and territorial authorities.

Why Luna is not presented as a drone

Lift and restraint, not remote navigation.

The current engineering concept is a lighter-than-air body supported by helium, with no propulsion and continuous physical anchoring to fixed ground points. Its remote functions manage light, sensing, telemetry, shutdown, and safety; they are not intended to steer a free trajectory.

  • The working classification is a tethered gas aerostat, subject to confirmation against the final configuration.
  • A radio link does not automatically make the system remotely piloted; the legal effect of each control function is one of the ENAC questions.
  • ATM-05B nevertheless applies ATM-09 airspace criteria and procedures by analogy to this type of tethered unmanned aerostat. Product classification and airspace procedure must therefore remain distinct.
  • The 2026 UAS Geographic Zones draft is not in force. If adopted, it would repeal ATM-09A and may require ENAC to explain the new reference used by ATM-05B.
  • Only ENAC or another competent authority can give a binding or case-specific classification and procedural direction.

Official source set

Read the authority, then read our limits.

These links lead to EUR-Lex, ENAC, Normattiva, and Regione Liguria. The summaries are deliberately short and do not replace the complete official text or later amendments.

EU-01

Regulation (EU) 2018/1139 · Annex I, point 2(a)

Conditional national-regime perimeter for non-propelled tethered aircraft with a tether no longer than 50 m and the specified mass or volume limits.

Open official source

EU-02

Regulation (EU) 2018/395 · Article 1(2)

The EU balloon-operations regulation expressly does not apply to air operations with tethered gas balloons.

Open official source

EU-03

Regulation (EU) 2019/947 · UAS operations

If Luna's final configuration is confirmed within the Article 2(3)(d) and Annex I exclusion, this harmonised UAS operating regime would not be the direct product-and-operation framework. National rules and ENAC's ATM analogy would still remain relevant.

Open official source

EU-04

Regulation (EC) 785/2004 · insurance

The EU minimum-insurance regime excludes captive balloons from its scope. That does not remove liability or the need for suitable cover; the residual national position and an operation-specific policy remain open workstreams.

Open official source

IT-01

ENAC · Balloon flight operations

ENAC states that tethered gas balloon operations remain regulated nationally and links to the national passenger-carrying framework.

Open official source

IT-02

ENAC · Passenger tethered-balloon rules

The national rules expressly available on ENAC's website concern tethered balloons intended to carry persons; Luna is not designed to carry persons.

Open official source

IT-03

Navigation Code · Article 709

Works that interfere with protected surfaces can constitute obstacles; fixed or mobile obstacles require ENAC authorisation. Application to a particular Luna site remains site-specific.

Open official source

IT-04

ENAC · Obstacles and dangers assessment

ENAC explains the relationship between Article 709, airport safeguarding maps, municipal technical offices, and central compatibility assessments.

Open official source

IT-05

ENAC · National air-operations requirements · 6 November 2025

For Annex I balloons, the national regulation adopts Part-BOP for non-commercial and commercial operations. Whether and how that imported framework reaches an unmanned tethered system remains an open question for Luna.

Open official source

IT-06

ENAC Circular ATM-05B · sections 5.1(g), 7.2, and 7.3

The circular expressly covers unmanned, non-powered tethered balloons and aerostats, applies ATM-09 airspace criteria and procedures by analogy, and treats laser or light-beam emissions separately.

Open official source

IT-07

ENAC Circular ATM-09A · geographic-zone procedures

The current published circular describes UAS geographic-zone and airspace-reservation procedures referenced by ATM-05B's analogy.

Open official source

IT-08

ENAC draft · UAS Geographic Zones · 24 June 2026

A draft under consultation until 24 July 2026 would repeal ATM-09A if adopted. It is not in force; its possible effect on the ATM-05B analogy and transitional procedure must be confirmed.

Open official source

IT-09

ENAC · UAS-IT Regulation

An adjacent framework reviewed as a conservative comparison only. Direct application to Luna is not assumed.

Open official source

REG-01

Liguria Regional Regulation 5/2009 · outdoor light

Article 9 prohibits temporary luminous aerostatic balloons when used as advertising or recreational attractions and when they scatter light towards the sky. Luna's functional, shielded, downward-lighting distinction must be verified with the Region and municipality; it is not treated as an acquired exemption.

Open official source

IT-10

Legislative Decree 81/2008 · worksites

A construction-site use case also requires workplace-risk, coordination, equipment, interference, and emergency controls. Aviation classification cannot replace those duties.

Open official source

Authority dialogue

Ten questions remain open.

The ENAC page records the questions and the communication status without publishing signed filings, receipts, protocol records, or confidential annexes.

Review the ENAC questions