Luna · regulatory review
A public review of Luna’s primary lighting configuration: what official sources already establish, the three remaining ENAC questions, and the technical and site checks still to complete.
Assessment dated 15 October 2026 for the update of report L-LUNA-001. The stated design is not a tested or certified configuration. Luna remains in research and development and is not offered for sale or public operation.
Illustrative diagram · closed envelope; ground tether not shown. Not a validated 3D/CAD model or measured photometry.
The model being assessed
Functional lighting is Luna’s primary purpose. Luna remains a closed sphere: the envelope is dark, opaque aluminised Mylar, with declared visible transmission close to zero, except for a small curved transparent membrane section at the bottom. That transparent material completes the closed envelope. LEDs sit low inside; useful light passes through the membrane in a downward cone that widens towards the ground. The rest of the lower hemisphere remains opaque.
They define the intended configuration for legal screening. They are not test results. The complete internal solid core below 250 g is not the total airborne or potentially falling mass. The 100 klm reference is an illustrative design scenario. Full angular photometry, operating tilt, retention, wind limits and emergency recovery remain to be demonstrated.
Primary configuration
Luna studies elevated functional lighting for construction sites, events, yards and large outdoor spaces. A helium aerostat remains continuously tethered to the ground and recoverable. Temporary and longer-lasting removable installations are studied; lighting is the principal function.
Findings from official sources
Known thresholds and procedures are findings, not further questions for ENAC. The remaining uncertainty concerns a specific national title, the light-beam provision and the rules of the air for low tethered stationing above people or crowds.
For the stated non-propelled tethered aerostat, Annex I, point 2(a)(ii), of Regulation (EU) 2018/1139 provides the volume-based exclusion: complete tether up to 50 m and maximum design volume below 40 m³. The actual configuration must meet these conditions; the internal core’s 250 g target does not determine this exclusion.
ATM-05B section 7.3 already refers to ATM-09 criteria and procedures. Within permitted heights and distances, no request is required; outside them, the referenced reservation procedure applies. This airspace analogy does not automatically make every harmonised UAS product or operator obligation applicable. It does not replace applicable rules of the air, including minimum-height and overhead-people requirements.
Keeping the entire system below 24 m avoids reaching airport-zone bands that start at 25 m. It does not overcome zones restricted from ground level, obstacle safeguards or other site conditions. Check current maps, coordinates, the full operating envelope and the planned duration before each installation.
The 1999 tethered-balloon regulation concerns remunerated passenger transport. The 2025 national operations regulation has its own scope and definitions; its Part-BOP references do not directly settle Luna’s unmanned case. Q1 therefore asks only which specific aircraft or operator title is required, if any, and on what legal basis.
ATM-05B section 7.2 already describes the procedure for laser or light-beam activity. Q2 concerns only whether Luna’s functional downward lighting through a transparent lower portion of the closed envelope in an otherwise opaque spherical envelope falls within that notion. Photometry, glare and optical-safety measurements remain engineering work; a clearance is not sought on unmeasured data.
The Annex I exclusion concerns the Basic Regulation and the acts adopted under it; it is not an exemption from every rule of the air. SERA and RAIT contain safety and minimum-height provisions. Their coordination with low captive stationing and ATM-05B section 7.3, particularly directly above people or crowds, is the specific unresolved point in Q3.
Feasibility assessment
The primary design supports a materially more favourable prospect of lawful use: no propulsion, an ordinary height below 24 m and shielded downward functional lighting. No general prohibition on designing or using such a lighting aerostat has been identified in this review. This assessment is not a conformity certificate for a built product or every site.
Events
A wedding, party or concert needs its own assessment of people, the overhead footprint, controlled areas, recovery and event responsibilities. The low-height design alone does not establish permission to place Luna above a crowd.
Read the event assessmentConstruction sites
A controlled construction site requires a configuration-specific risk assessment and coordination with the site’s responsible parties. Workers, other activities, electrical equipment, anchors and emergency access remain part of the operating case.
Read the worksite assessmentIndependent compliance work
These are configuration and site workstreams for the responsible technical and legal parties. They are not additional ENAC questions, completed checks or a claim that every listed rule necessarily applies.
Product safety: requirements and evidence
Open · configuration and site
Measure the full angular distribution, glare and optical safety in nominal and tilted positions. In Liguria, apply the relevant photometric requirements, protected-zone rules and any actual exclusion or municipal procedure. Functional use and temporary installation are not automatic exemptions.
Open · fitted equipment
Assess power supplies, cables, protections, EMC, radio integration, spectrum conditions and applicable cybersecurity requirements. Low voltage or compliant individual modules do not demonstrate the safety or conformity of the complete assembly.
Open · engineering evidence
Document masses, volume, restraint and recovery, anchor loads, wind limits and failure behaviour. Assess the low-pressure envelope separately from cylinders, regulators, storage and transport; evaluate any powered winch as actually configured.
Open · before each activity
Check airspace and obstacles, lawful land use, workers and third parties, weather, access and emergency arrangements. Construction sites, public events, fire safety, planning and ecological constraints retain their own competent parties and procedures.
Conditional · future modules
Connectivity services, site monitoring, cameras and thermal imaging require a separate scope and compliance review before activation. If personal data or workers are involved, assess purpose, legal basis, minimisation, security and any required impact assessment or workplace safeguards.
Open · before an offer
Fix the configuration and manufacturer’s role; determine the applicable product and end-of-life rules, manuals, maintenance, training and insurance. Operated service, sale and rental have different responsibilities. No market-ready product or verified insurance policy is claimed.
Regulatory library
Search by topic, act, article or intended use. Each source has a stable reference, relevant provisions, an explanation of its scope for Luna, evidence still needed and a dated verification note. The structured catalogue is also available for automated consultation.
Authority dialogue
The short report and PEC text are prepared for signature and dispatch. Neither a submission nor an ENAC answer is claimed. Read the public question summary and communication status.
Review the ENAC questions