The Civil Aviation Authority Operating Safety Case for UK drone operations

As promised in my last post, here is the beginnings of a post on the operating safety case (OSC) which has been introduced by the CAA in the revised CAP 722 publication. I will try to be as accurate as I can, but as always there are a few grey areas so please contact the CAA for final confirmation! Please consider this post a work in progress!

The idea of the OSC is that it allows commercial drone operators in the UK to apply for an annual exemption to your standard permission that allows you to operate outside the limitations of your standard Permission for Aerial Work. Previously, exemptions were issued on a case by case basis, which has led to an almost unmanageable workload. The most obvious example is it is currently not permitted to fly a 7-20Kg drone in a congested area. This has led to the dangerous practice of weight-stripping; running fairly heavy drones on smaller battery capacities and stripping unnecessary (!??) weight in order to bring a drone below 7Kg (which DOES include batteries by the way, whatever people try to tell you!). A case in point here is the DJI S900 which naturally and comfortably comes in somewhere around 7.5Kg with a Zenmuse and GH4 with a sensible amount of batteries. I find it very hard to justify weight-stripping in order to claim that a machine running with dangerously low battery redundancy is now safer! The operating safety case would allow you to submit procedures for operating the 7-20Kg machine within the congested area. In order to do so you will have to incorporate extra risk mitigation in the design of your aircraft and/or through your operational procedures.

A congested area is defined by the CAA as “any area of a city, town or settlement which is substantially used for residential, industrial, commercial or recreational purposes”. Now, technically that means a town-based golf course is a congested area. This makes sense if you are flying a 747 but probably not when flying an S1000. But, whatever we think, those are the rules.

The OSC is not limited purely to 7-20Kg could also be used to apply for reduced separation distances across the 0-20Kg spectrum., increased working height, EVLOS etc. The idea is that the CAA is moving towards a “concept of operations” (ConOps) approach so that the mass boundaries themselves become relatively unimportant and the key aspect is risk.

conops approach

Figure 1: ConOps approach to drone operations (CAA CAP722)

As you can see from this graph, the right-hand side above 20Kg is irrelevant to most users at present.

So, there are three risk categories, A, B and C. Three factors increase the risk of a given operation:

  • Increasing aircraft mass
  • Increasing aircraft technical complexity
  • Increasing operating environment complexity

So, basically, if you are running a Phantom in a farmer’s field in Norfolk the risk will probably fall into category A. If you are running a 19.9Kg machine beyond line of sight in central London it will be C. It is likely that most people’s operations will fall into category A or B.

I’ll pick that up again later.

The next stage of the OSC is the paperwork you need to produce to submit to the CAA.

The paperwork is divided into three volumes:

  1. Volume 1: The Operations Manual
  2. Volume 2: Systems information
  3. Volume 3: Safety Assessment

The CAA have provided templates in the appendices B-D of CAP 722.

Volume 1 is effectively what we have been writing for 0-20Kg operations up until now. If you wish to apply for a standard PfAW, it is all you need to complete.

Volume 2 should contain as much information as possible about the RPAS you wish to be covered by the OSC. The main focus should be on risk mitigation so your volume 2 could include (but isn’t limited to):

  • Mass considerations
  • Failsafe features
  • Any design and manufacturing standards
  • Full details of the flight envelope (where and how it can be used)
  • Payload details
  • Full aircraft details
  • Single points of failure
  • Additional safety features etc.

Full information can be found in appendix C of CAP 722 but the CAA want you to fully understand your machine, its limitations, how it functions and how it can be made as safe as possible.

Volume 3 gives details of your safety management beyond the aircraft itself and includes sections for risk assessment and self assessment. So, effectively, the idea is to assess as fully as possible the risks associated with the operations you wish to include in your OSC and also to assess the limitations of your crew and procedures. A template is available in appendix C of CAP 722. As you will be applying for an annual OSC it is probably best to try to envisage what you are likely to want to do and to think generically rather than too specifically at first, so think of the type of location you are going to fly at rather than specific locations. Are there any common safety issues between sites. for most people it will tend to be proximity issues that need to be risk assessed.

Going back to the graph from earlier (figure 1), the aim of your volumes 2 and 3 should be to develop equipment and/or procedures that mitigate the risks associated with either the increased mass or increased environmental complexity.

I will try to add to this soon to give more detail on risk matrices and the self assessment method preferred by the CAA. I’m afraid we can’t give direct assistance with individual operating safety cases at the moment as every case is likely to be different and the CAA really want you to take ownership of the process.

This information is as correct as we can get it at the time of publication but may be out of date by the time you read it so please check current guidelines and feel free to contact us if you need more information.

Fly safe!

Elliott- HexCam

To be continued… probably!

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The changing face of UK drone pilot qualifications

My original post about routes through to obtaining a Civil Aviation Authority (CAA) Permission for Aerial Work (PfAW) is now a little out of date! A lot has changed in UK drone legislation in the last few months so I thought I’d put out a bit of an update. I will try to keep this simple but things seem to have got messier than ever really.

So, let’s start at the end! At present, in order to operate any drone commercially in the UK you need to obtain a PfAW. The PfAW is divided into two categories; 0-7Kg and 7-20Kg. The 0-7Kg permission is slightly less restrictive but still sets high safety expectations.

In March 2015 the Civil Aviation Authority updated their core UAS guidance publication, CAP 722.

One change detailed in CAP 722 means that operators who already have manned aviation experience have the opportunity to take an alternative route to a PfAW. So if you already have a PPL, CPL, microlight licence, gliding qualification or military experience you may be able to go through our flight assessment only process. Please see page 47 of CAP 722 for more details or give us a call to find out more!

Another change is that operators who hold a BMFA A or B certificate for the type of aircraft they wish to fly can now apply directly to the CAA for a PfAW with no further qualifications or assessment necessary. for multirotors, either a helicopter or multirotor A certificate is acceptable.

A further change means that it is no longer necessary to pass assessments on every aircraft you wish to fly or to inform the CAA if you wish to use new aircraft within your assessed categories. One assessment per category (0-7Kg or 7-20Kg) is all you need. there is no requirement to renew your pilot qualification annually as long as you keep your currency up-to-date: at least 2 hours flying every three months. You are required to renew your PfAW annually.

So what do you actually need to do to get a PfCO?

Ah, you noticed the change from PfAW to PfCO! As of August 2016, it is now called a Permission for Commercial Operations.

The CAA are interested in four areas that they call critical elements:

  1. Theoretical knowledge
  2. Initial practical flight assessment
  3. Operations manual
  4. Experience requirement

You apply for a PfCO using form SRG 1320.

So, let’s try to be logical.

As far as the CAA are concerned, in terms of the critical elements above:

  • If you have a BMFA A or B certificate, you already have 1, 2 and probably 3 if you are a regular flyer. If not, get out and fly. I would strongly recommend you read CAP 722 before applying though. You still need to apply and get your PfCO before operating commercially.
  • If you are involved in manned aviation you probably already have 1. You need to get a flight assessment which we can do for you. Get yourself up to speed on the latest UK drone legislation by reading CAP 722 as working outside your aircraft changes things slightly! You will need to make sure you get adequate experience on your RPAS before the assessment. If your manned qualification is expired you will need to contact the CAA to find out if they will accept it. They will not accept expired PPLs, if they expired before 31st December 2009.
  • If you have no previous manned experience and no BMFA certificates, you will need to go through a qualification with one of the full NQEs listed below.

What is an NQE?

An NQE (a National Qualified Entity), is an organisation approved by the CAA to recommend people for a Permission for Commercial Operations.

Restricted NQEs

Restricted NQEs can carry out flight assessments for drone pilots who already have manned aviation experience as described above or satisfy the theoretical knowledge element in some other way. Restricted NQEs can’t offer theory assessment.

Full NQEs

Full NQEs can carry out theory and flight assessments for drone pilots who have no previous formal experience. The NQEs all have their own qualifications or certifications, which tend to differ in delivery style, but as far as the CAA are concerned they are all equally acceptable for applying for a permission for aerial work. Some NQEs claim their offerings are more internationally recognised but it is worth checking carefully with both the NQE and the aviation authority in any other countries you may wish to operate in. Prices and timescales of theory courses also vary with some NQEs using distance learning to enable a shorter theory course. The name of the qualification offered is in brackets.

The Aerial Academy (TAAC): www.theaerialacademy.com

Whispercam (UAPQ-s): www.whispercam.co.uk (now running courses at our Norwich location)

Aerial Motion Pictures (ICARUS): www.aerialmotionpictures.co.uk

Resource Group (RPQ-s): www.resourcegroup.co.uk

Rheinmetall Technical Publications UK Ltd (RPCS): www.uastraining.com

EuroUSC (BNUC-S): www.eurousc.com

What next?

Please feel free to contact us via The Aerial Academy if you need more information. We can also provide basic and advanced flight training and can recommend and supply drone equipment including most DJI equipment and a full custom build service.

I’ve heard about operating safety cases (OSC) what are those?

Basically, if you want to operate outside a standard PfAW, particularly flying 7-20Kg machines in congested areas or if you want to fly at greater heights or closer than standard distances you will require an OSC. Here is my blog post on operating safety cases, but I strongly recommend you read CAP 722 before embarking on any of this. It really is very helpful once you get your head around it!

 

As always, fly safe! This information is as correct as we can get it at the time of publication but may be out of date by the time you read it so please check current guidelines and feel free to contact us if you need more information.

Elliott – HexCam

UK telephone: 01603 881985