What permissions are required for drone surveying? 6 commonly overlooked items

Table of Contents

• Fundamental assumptions to grasp first in drone surveying

• Flight Permissions and Approvals under the Aviation Law

• Aircraft registration and Remote ID

• Prohibition of flights around important facilities and advance notification

• Consent from Land and Facility Managers and Confirmation of Ordinances

• Road Use Permit / Road Occupancy Permit

• Flight plan notification

• How to ensure permission checks are fully completed on-site

• Summary

Key prerequisites to grasp first in drone surveying

When checking permissions for drone surveying, the first thing many officers think of is flight permissions and approvals under the Aviation Law. Of course those are important, but in practice looking only at that is not enough. When flying an unmanned aircraft weighing 100 g or more outdoors, the system manages the whole process as a series of steps, including aircraft registration, flight permissions and approvals, notification of flight plans, and the response in the event of accidents, etc. Moreover, flight permissions and approvals under the Aviation Law are not uniformly required for all flights; whether an operation falls under specified flight, and further whether the aircraft has certification or the pilot holds a competency certificate, changes whether they are needed. In other words, the first thing you should do is not “obtain permission,” but “classify what category this flight falls into.”

What is even more easily overlooked is that obtaining permission or approval under the Aviation Act does not, by itself, allow you to fly anywhere. The Ministry of Land, Infrastructure, Transport and Tourism notes that there are places and areas where flight is prohibited due to regulations around important facilities and prefectural and municipal ordinances, and advises that, separately from applying for flight permission or approval, you should confirm whether flight is permitted in that area and complete any necessary procedures with the managers, etc. The National Police Agency also makes clear that flight is prohibited by other laws in the airspace over important facilities and roughly 300 m (984.3 ft) around them. What on-site personnel truly need is the perspective of overlaying "national flight permission", "consent from the site's manager", and "additional procedures for each location, such as roads and parks" on a single map.

In drone surveying, whether photogrammetry or laser surveying, the practical issues that often arise are flights in densely populated areas, flights beyond visual line of sight (BVLOS), maintaining distance from people and property, areas around airports, securing takeoff and landing sites, and measures for passersby. At small urban sites and roadside locations, it is often not the airspace to be flown but the takeoff/landing and monitoring arrangements that require procedures. This article, with those kinds of on-site stumbling blocks in mind, organizes six easily overlooked items in order.

1. Flight Permissions and Approvals under the Aviation Law

First, what must be confirmed is whether the survey flight in question qualifies as a specified flight under the Aviation Law. National guidance lists typical cases as: around airports, in airspace reserved for emergency operations, airspace at or above 150 m (492.1 ft) above the ground or water surface, over densely populated areas, night flights, flights beyond visual line of sight, flights within 30 m (98.4 ft) of people or property, over event sites, transport of hazardous materials, and dropping objects. In drone surveying, the issues that tend to arise in particular are densely populated areas, beyond-visual-line-of-sight operations, sites where distances to people or property are likely to be small, and sites around airports or with high-elevation terrain, and this is where the regulatory entry point lies.

What’s important here is that surveying does not automatically require permission, nor is it automatically exempt just because it’s surveying. The criterion for judgment is always the airspace in which you fly and the way you fly. For example, if you fly in an open suburban area during the daytime, within visual line of sight, and keep a sufficient distance from third parties, the operation may fall into a category that does not require permission or approval under the Aviation Law. On the other hand, even the same surveying task can quickly become a specified flight if it involves conditions such as photographing roofs or alongside roads in urban areas, following linear structures and going beyond visual line of sight, or approaching people or property in a narrow construction yard. It is important to judge based on how the flight is conducted, not on the name of the surveying task.

If you plan to fly near an airport or at an altitude of 150 m (492.1 ft) or higher, simply submitting an application is not sufficient. The Ministry of Land, Infrastructure, Transport and Tourism advises that, near airports, prior coordination with airport operators and air traffic control authorities is required, and that for airspace at altitudes of 150 m (492.1 ft) or above you must coordinate with the air traffic control authority that has jurisdiction over the airspace before applying for permission. Also, airspace reserved for emergency operations cannot be flown in even if you have a regular flight permit. Because the situation can change when disaster response or rescue activities are underway, it should also be noted that verifying the status of the airspace on the day may take precedence over whether you have a permit.

Another common misunderstanding is the belief that "if you have a national qualification, no application is necessary." In reality, if aircraft certification and the pilot's competency certificate are both in place, permission/approval may not be required for some specific types of flights, but not for all. According to the government's explanation, there are cases in which permission/approval can be waived for aircraft with a maximum takeoff weight of less than 25 kg when conducting flights at night, beyond visual line of sight, or flights where distance from people or property cannot be maintained, provided that access control measures are implemented and necessary safety measures are taken. Conversely, situations such as areas around airports, at altitudes of 150 m (492.1 ft) or higher, over event sites, transporting hazardous materials, dropping objects, and total weight of 25 kg or more will still require individual permission/approval regardless of whether certification or competency proof is held. In practice, rather than assuming "it's fine because I have the qualification," you need to reconfirm which category of flight applies.

Do not take the application timing lightly. The national portal advises submitting applications at least 10 business days before the planned flight start date, and the Ministry of Land, Infrastructure, Transport and Tourism itself urges allowing a margin of about 3-4 weeks to allow for responses to any deficiencies. If you will repeatedly fly over the same location for a certain period, a comprehensive application valid for up to one year is also possible. In surveying projects the time from site confirmation to flight is often short, but if the flight requires permission, failing to factor in processing days at the estimate and scheduling stage can mean you are technically able to fly but are stopped for legal or operational reasons.

2. Aircraft Registration and Remote ID

Even before permissions and approvals under the Aviation Law, there is a more basic oversight: aircraft registration. The national registration portal states that unmanned aircraft weighing 100 g or more must be registered, and that unmanned aircraft of 100 g or more that are not registered may not be flown. Furthermore, once a registration mark has been issued, in addition to displaying the registration mark on the aircraft, equipping it with Remote ID functionality is, in principle, required. Surveying and construction companies often own multiple aircraft, and if the person in charge focuses only on whether permissions are in place and puts off checking whether the aircraft are actually in a flyable condition, operations can be halted the day before going to the site.

Registration is not a one-time process. The registration is valid for 3 years, and if the renewal has lapsed you cannot fly. In addition, applications for flight permission and approval and notifications of flight plans are designed to proceed based on registered aircraft information. The Ministry of Land, Infrastructure, Transport and Tourism explicitly states that to carry out flight permission and approval procedures you must have been issued a registration mark or a test flight notification number, and the online procedure flow also indicates that applications and notifications should be submitted based on registered aircraft information. In operational practice, clarifying within the company who the pilot is, who the operator is, and which aircraft will be flown is the first step in complying with regulations.

On surveying sites, special attention is required when borrowing an aircraft from a partner company or when multiple departments share an aircraft. It’s not enough to check whether it’s registered; you must make sure which aircraft number, which pilot information, and which application it’s linked to are all aligned, otherwise the application details and on-site operations will conflict. Before getting into permit matters, confirming first that "the aircraft to be flown is registered and that its markings, identification, and operational information are in order" is ultimately the quickest approach.

3. Prohibition of Flights Around Critical Facilities and Prior Notification

The third oversight is regulations around important facilities. According to guidance from the National Police Agency, flight of small unmanned aircraft, etc., is prohibited in the airspace over important facilities and the surrounding area of approximately 300 m (984.3 ft). The targets include nationally important facilities, foreign missions, defense-related facilities, airports, and nuclear facilities. In other words, even places that appear to be flyable under the Aviation Law may be prohibited by another law. For urban infrastructure inspections, surveys around public facilities, and construction surveys around airports, skipping this verification can undermine the entire plan.

Moreover, this regulation does not mean you only need to be careful directly above the facility. It applies not only to the airspace over the site or area, but also to the airspace up to roughly 300 m (984.3 ft) around it. Even where flight may be permitted as an exception, it is limited to those who have obtained the consent of the manager of the relevant facility, the landowner or someone who has obtained their consent, or flights conducted for the operations of national or local government. Furthermore, in the red zones of designated defense-related facilities and designated airports, the landowner’s consent alone is not sufficient; consent from the facility manager is required. In practice, if you think “there may be an important facility nearby,” it is safer to check on a map before doing an on-site survey.

One more important point is that prior notification is required even in cases that fall under exceptions. The National Police Agency advises that, even when an exception to the flight prohibition applies, if you intend to fly over the target facility and the surrounding area of approximately 300 m (984.3 ft), you must notify the prefectural public safety commission or equivalent authorities. On the national map, the scope of such areas around target facilities can be checked overlaid with densely populated districts and the regulatory zones under the Aviation Law. Especially for surveys in urban areas, the maps under the Aviation Law alone are not sufficient for judgment; it is essential to also overlay the National Police Agency’s regulatory zones.

4. Consent of Land and Facility Managers and Confirmation of Ordinances

The fourth is coordination with land and facility managers. The Ministry of Land, Infrastructure, Transport and Tourism states, separate from flight permission and approval applications, that there are locations and areas where flying is prohibited under prefectural, municipal, and other ordinances, and that you must confirm whether flight is permitted in the area where you wish to fly and complete the necessary procedures with the managers. If this is omitted, you can end up in the most regrettable situation of having national permission but being unable to access the site. Coordination with managers is as important as legal compliance for construction sites, factory premises, schools, hospitals, parks, ports, and river areas.

This issue is not as simple as saying that consent is always required for private land and not required for public land. In practice, you need to coordinate in advance with site managers on matters including the use of takeoff and landing locations, access control, handling passersby, considerations for noise and privacy, and facility preservation. Even the Ministry of the Environment’s guidance for national parks requests prior confirmation because land managers or owners may prohibit flights over their premises, and it advises refraining from using places where users gather or where privacy would be compromised. This approach does not apply only to parks; it equally applies to tourist sites, areas adjacent to residential housing, and public spaces.

Also, in places such as natural parks, rivers, and national forests, permissions directly tied to the flight itself are not always uniformly required, but procedures may arise due to additional actions or local rules. The Ministry of the Environment notes that while flights and takeoffs and landings within national parks may, in some cases, not require permit applications or notifications under the Natural Parks Law, prior applications can become necessary if the installation of structures is involved; that for rivers it may be necessary to check the rules of the managers or surrounding municipalities; and that in national forests an entry notification may be required. At surveying sites, it is safer to check not only whether flight is allowed but also securing takeoff and landing sites, markings, placement of assistants, and vehicle staging areas.

5. Road Use Permit and Road Occupancy Permit

The fifth point concerns procedures related to roads. This is an area that is easily overlooked. According to a notice from the National Police Agency, merely having an unmanned aircraft fly over a road does not, in principle, require a road-use permit. In other words, the understanding that “a road-use permit is automatically required because it flies over a road” is not accurate. What matters is what you do on the road. If you take off or land on the road, pilot the aircraft there, perform related work, station assistants to prevent third parties from entering, place signboards or similar items, or conduct operations that cause people to gather and significantly affect normal traffic, then the question of whether a road-use permit is required arises.

In surveying practice, the question of precisely "what to do on the road" becomes the issue. It is not uncommon to set up the aircraft at the roadside, place assistants on sidewalks or shoulders, put out warning signs or cones, or temporarily reorganize traffic flow to ensure the safety of passersby. The national administrative procedures casebook also indicates that when placing warning signs or the like on a roadway, a road-use permit under the Road Traffic Act or a road-occupancy permit under the Road Act may be required. Road-occupancy permits fall under the jurisdiction of the road administrator. Therefore, in roadside surveying it is practical to decide, before obtaining flight permission, "where to place the takeoff and landing area," "where to position assistants," and "whether to deploy signs or safety equipment," and to confirm these with both the police and the road administrator.

Especially for small-scale projects in urban areas, you are more likely to be held up by road procedures than by air-related ones. Even if the subject of filming or surveying is small, conditions such as narrow sidewalks, nearby intersections, or overlap with school commute times may require road-side adjustments for on-site safety. Conversely, if you address this issue at an early stage, you can significantly reduce failures where "the Aviation Law application was approved but you cannot fly at the site."

6. Notification of Flight Plan

The sixth is notification of the flight plan. This is a procedure that is easily overlooked after obtaining permission or approval. The Ministry of Land, Infrastructure, Transport and Tourism advises that those conducting specified flights are required to notify the Minister of Land, Infrastructure, Transport and Tourism in advance with a flight plan that specifies the flight date and time, route, and other details, and it clearly states that conducting specified flights without such notification is subject to a fine of up to 300,000 yen. In other words, simply going to the site with a permit is not enough; for each flight to be carried out, the administrative preparations are only complete once the advance plan notification has been submitted.

Under this reporting system, not only is submitting your own flight plan required, but it is also assumed that you will check other unmanned aircraft flight plans and no-fly zones. The government's online procedure guidance also shows that, before flying, you should check other flight plans, no-fly areas, and manned aircraft takeoff and landing areas and then report your own flight plan. At surveying sites it is common to fine-tune start times and flight routes due to weather or on-site circumstances, but if changes or deletions are necessary they must be reflected before the flight begins. Furthermore, for specific flights the creation of a flight log is also required. It is important not to treat permits and approvals as "just obtaining paperwork" but to design operations to include reporting, record-keeping, and, if necessary, accident reporting.

How to complete permission checks on-site

To reduce uncertainty in practical work, fixing the order of checks is effective. First, plot the site address and candidate takeoff and landing locations on a map, and overlay and review whether there are densely populated areas, proximity to airports, altitude conditions, and proximity to important facilities. Because densely populated areas are designated based on the national census, it is safer to verify using national maps or statistical maps rather than relying on outdated impressions. Next, check whether the location is subject to ordinances or management rules, and coordinate with the project's prime contractor, facility managers, managers of parks and waterways, and, if necessary, the police and road authorities. Confirming both the flight location and the takeoff and landing locations at this stage will greatly reduce later rework.

On that basis, determine whether the flight qualifies as a specified flight, and apply for permissions and approvals under the Aviation Act if necessary. If operating near an airport or at or above 150 m (492.1 ft), carry out advance coordination with airport authorities first; for repetitive projects, consider applying for a blanket approval. Submit applications at least 10 business days in advance, and preferably allow about 3–4 weeks. Receiving permission is not the end: notify authorities of the flight plan before execution, and keep a flight log after the flight. Making this sequence the standard procedure for projects reduces the likelihood of omissions even when personnel change.

Also, it is important not to leave roles ambiguous within the company. If it is unclear whose aircraft will be used, who is registered as the pilot, or which permit applies to which project, both regulatory compliance and safety management will break down. Quality control in surveying begins not only with the deliverables after flying but with the preparation of procedures before flight. Companies that can organize site conditions at the permit-confirmation stage find actual flights proceed more smoothly and achieve more consistent results.

Summary

The permissions required for drone surveying are not completed with a single permit. Centered on flight permissions and approvals under the Aviation Law, aircraft registration, regulations around critical facilities, consent from landowners and facility managers, road-related procedures, and notification of flight plans all overlap to make an operation lawful and executable. What is easy to overlook is that permission to fly and the consent or coordination required to conduct work at a given location are separate things. Whether you can separate and organize these two will greatly affect the accuracy of on-site preparations.

After permission checks are completed, on-site pre- and post-flight position checks, supplementary ground measurements, and the recording and sharing of coordinates become just as important. At sites where you don’t want a drone survey to end with a single flight but instead want to link the whole process from ground verification to recording, combining a smartphone-mounted GNSS high-precision positioning device like LRTK makes it easier to carry out pre-measurement preparation and post-measurement organization. In practical work, it’s not only whether you can fly that matters, but how you measure and how you preserve the results — arranging those details is what ultimately makes the difference.