Preparing your UAS operations manual for the CAA

Please note: This post is fairly out of date. Some of the information is still useful but please see this post as well.

Even now, a couple of years after I got into this industry, there appears to be a lot of confusion about the format and purpose of the UAS, RPAS or UAV Operations Manual that is required by the Civil Aviation Authority (CAA) when registering for Permission for Aerial Work (PFAW) in the UK. As a result I thought I’d just write down a few thoughts now and maybe add to it later.

As always, a little disclaimer: I get a lot of questions about multirotor equipment so I thought I’d start creating some posts about that. Please bear in mind that I learn a lot from reading around the blogs and forums and talking to people in RC shops so any inaccuracies are completely due to my own misunderstanding. By reading this you accept that, although I hope it will aid with your own understanding, it is written in good faith and I can’t take responsibility for any damage to yourself or your equipment that occurs through the use of this information. If you see anything that I have got wrong or you feel is dangerous, please contact me through the HexCam website or Facebook page and I will rectify it as soon as possible.

What is the Operations Manual not?

1) It is not an instruction manual: Occasionally I get people sending me an Operations Manual for review and it is a print out of a Phantom or Wookong manual. So the first thing to say is an Ops Manual is NOT an instruction manual for your RPAS. There will be aspects of the Ops Manual that describe some of the functions but your system and transmitter instruction manuals should only feature as documents for reference in the manual.

2) It is not a “paperwork exercise” to be shoved in a drawer once you get your PFAW: Your Ops Manual is an absolutely key document that should be very carefully thought through and should be regularly used and updated in line with experience and the evolution of your business. If you feel it is just a hoop to jump through and are not prepared to read through the relevant CAA documentation (which isn’t a huge amount) then I suggest you walk away from this profession now.

So what is your Operations Manual?

Put very simply, your Ops Manual covers four things: Who you are, what you are flying, what you want to do with your RPAS and how you will do it safely.

The core remit of the CAA is to ensure that all airspace users are operating in a way that ensures the safety of the public, property and other airspace users. As a result, the Ops Manual for the CAA only needs information about your RPAS to the extent that it impacts safety. So things like failsafe procedures will feature. Privacy will not feature, although I would suggest that you also begin to think about putting together some kind of privacy and data protection policy to hold separately within your business.

Resource Group who run the RPQ-s and EuroUSC who run the BNUC-S both provide information and guidance on production of the Ops Manual when you carry out your theory ground school. Both companies also offer different levels of Ops Manual review, including paid options.

You can also find a basic template on the CAA website as an appendix to CAP 722 (Section 3, Chapter 1, Annex 1) which on the PDF starts on page 73! There is also a direct link from the CAA UAS pages.

If completing the BNUC-S, you will be required to submit a completed Operations Manual for approval in advance of your flight examination and you will not be able to complete the flight examination until the Ops Manual has been approved by EuroUSC.

If completing the RPQ-s the Ops Manual does not have to be completed before the flight examination, but, as you have to demonstrate your operating procedures and use flight reference cards during your examination, it makes a lot of sense to complete the manual before the examination if possible.

If you are writing a manual for a “standard” Permission for Aerial Work, then your sections safety and incident management really need to address how you will work safely within articles 138, 166 and 167 of the Air Navigation Order:

Article 138: A person must not recklessly or negligently cause or permit an aircraft to endanger
any person or property.

Article 166: (1) A person must not cause or permit any article or animal (whether or not attached to
a parachute) to be dropped from a small unmanned aircraft so as to endanger persons
or property.
(2) The person in charge of a small unmanned aircraft may only fly the aircraft if
reasonably satisfied that the flight can safely be made.
(3) The person in charge of a small unmanned aircraft must maintain direct, unaided
visual contact with the aircraft sufficient to monitor its flight path in relation to other
aircraft, persons, vehicles, vessels and structures for the purpose of avoiding
collisions.
(4) The person in charge of a small unmanned aircraft which has a mass of more than 7kg
excluding its fuel but including any articles or equipment installed in or attached to the
aircraft at the commencement of its flight, must not fly the aircraft:
(a) in Class A, C, D or E airspace unless the permission of the appropriate air traffic
control unit has been obtained;
(b) within an aerodrome traffic zone during the notified hours of watch of the air
traffic control unit (if any) at that aerodrome unless the permission of any such
air traffic control unit has been obtained; or
(c) at a height of more than 400 feet above the surface unless it is flying in airspace
described in sub-paragraph (a) or (b) and in accordance with the requirements for
that airspace.
(5) The person in charge of a small unmanned aircraft must not fly the aircraft for the
purposes of aerial work except in accordance with a permission granted by the CAA.

Article 167: (1) The person in charge of a small unmanned surveillance aircraft must not fly the
aircraft in any of the circumstances described in paragraph (2) except in accordance
with a permission issued by the CAA.
(2) The circumstances referred to in paragraph (1) are:
(a) over or within 150 metres of any congested area;
(b) over or within 150 metres of an organised open-air assembly of more than 1,000
persons;
(c) within 50 metres of any vessel, vehicle or structure which is not under the
control of the person in charge of the aircraft; or
(d) subject to paragraphs (3) and (4), within 50 metres of any person.
(3) Subject to paragraph (4), during take-off or landing, a small unmanned surveillance
aircraft must not be flown within 30 metres of any person.
(4) Paragraphs (2)(d) and (3) do not apply to the person in charge of the small unmanned
surveillance aircraft or a person under the control of the person in charge of the
aircraft.
(5) In this article ‘a small unmanned surveillance aircraft’ means a small unmanned
aircraft which is equipped to undertake any form of surveillance or data acquisition.

If you want to operate beyond these limitations on a regular basis, you need to apply for an exemption at the time you apply to the CAA for your PFAW. So, for example, you might wish to apply for increased altitude, closer separation distances or night flying. The CAA have stated that they are happy to receive applications for exemptions to standard permissions as long as you can provide an adequate safety case for the exemption applied for, these are considered on a case by case basis. The CAA also consider one-off exemptions.

The Permission for Aerial Work will look slightly different if your RPAS is heavier than 7Kg as it will include conditions for congested areas.

Where do I start?

Here is a starter list of things I would suggest you get together before you start:

  1. Coffee and biscuits
  2. Details and specs of your RPAS and cameras
  3. Links to instruction manuals for the RPAS, Transmitter, AV equipment, relevant CAA documents.
  4. Your company details if applicable.
  5. A list of potential applications for your RPAS.
  6. Your operating procedure (to include, how you setup before you fly, pre-flight checks, in-flight procedures (take-off, flight, landing), post-flight checks and emergency procedures).
  7. Think about what you would do in the event of an incident and how the RPAS would behave in response to events such as transmitter loss, motor failure, malicious interference, GPS signal loss.
  8. Insurance details.
  9. How you will survey and risk assess each flight site.

I suggest you stick to the CAA layout so it makes it easier for them to check your document, the skeleton documents provided by Resource UAS and EuroUSC broadly follow the CAA template.

The key thing is to make it a manual that YOU (and your employees) can use practically in the office and the field. Don’t see it as an Operations manual “for the CAA”; it is a manual for you, that details exactly how you and representatives of your business will operate safely and legally in UK airspace. You just have to get it approved by the CAA to get your Permission for Aerial Work.

Can we help?

Yes we can. We do provide assistance with Operations Manuals every now and again, using a model we have developed over the last two years, that has been approved by the CAA three times and was highly commended by EuroUSC. The cost will depend on the scope of your manual and will vary depending if it is a simple check of an already drafted manual or if it is a new manual to be written from scratch. Either way, we work closely with you to ensure that you take ownership of your manual, so that it is not just a copy of ours, but is a working document within your business.

No we can’t. I’m sorry but due to the increasingly rapid changes in legislation and the differing requirements of the NQEs we can no longer help with the operations manual process.

Any questions, you know where I am. Elliott – HexCam

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