SAM IS ....
CAA: CAP722G Released

CAP722G: Unmanned Aircraft System Operations in UK Airspace – Specific Category UAS Modification Policy

The aim is to allow certain technical changes to be made to the UAS during the validity period of an Operational Authorisation, without the need to apply to the CAA for a variation in the OA. It is intended specifically for companies doing R&D activities, however any operator could also include in its Ops Manual the relevant process enabling that implementation of minor technical changes.

CAP722G provides a definition and associated processes for a technical change to an Unmanned Aircraft System (UAS), which is described in Assimilated Regulation (EU) 2019/947 AMC1 UAS.SPEC.030(2).

Aim
CAP 722G provides a definition and associated processes for a technical change to an Unmanned Aircraft System (UAS), which is described in Assimilated Regulation (EU) 2019/947 AMC1 UAS.SPEC.030(2).

UAS.SPEC.030(2) requires a UAS Operator to apply for an update to their Operational Authorisation following any significant change to the operation.

AMC1 to this regulation currently sets out that a technical change may be considered a significant change.

This policy sets out that some technical changes are not significant, and so do not require a variation to an OA, as described in figure 1.

2nd May 2024

SAM IS ....
CAA Update at the ARPAS-UK Annual Conference 2024
  • Kevin Woolsey, Head of RPAS Systems at the Civil Aviation Authority (CAA)
  • Callum Holland, RPAS Sector Lead: Application at the CAA

Kevin Woolsey and Callum Holland joined the ARPAS-UK Team and Members at their Annual Conference to provide an update on CAA activities. The presentation was followed by Q&A. Any questions not answered in the session have been forwarded to Kevin and Callum for response.

The Presentation:

SAM IS ....
Drone integration: could Scotland’s Orkney Islands provide a blueprint?

A blueprint for effective integration of drones with crewed aviation into unsegregated airspace?

Airspace is a critical piece of infrastructure requiring modernisation to accommodate a new generation of crewed and uncrewed aerial vehicles. As part of a pioneering project, Highlands and Islands Airports Limited (HIAL), supported by Egis, have proposed an airspace design and operational concept that would allow drones to be integrated in an operational trial alongside crewed aircraft in uncontrolled airspace in the Orkney Islands. If successful, the trial will provide a blueprint that could be rolled out more widely across Scotland and the UK. Egis’ Richard Derrett-Smith and HIAL’s Pat Nolan explain more.

Outside of major conurbations and airports, as much as 70% of the UK’s airspace is uncontrolled, meaning that anybody can fly there, subject to some basic rules. This contrasts with controlled airspace, which is managed by air traffic controllers, with rules and communication protocols to keep airspace users safely separated. The problem is that the existing airspace structures and associated Air Traffic Service regulation for both controlled and uncontrolled aviation cannot currently accommodate the needs of all types of aircraft, including one of the fastest growing user groups: drones.

In Scotland’s Orkney Islands, uncrewed medium and heavy lift drones (100 – 300 kg) are already being used for fast collection and delivery of medical supplies, pharmaceuticals, and perishable goods, like shellfish – which are transported from outlying islands back to a hub airport at Kirkwall and then flown onward to places like London in a fraction of the time it would take for them to travel by ferry. However, to date, these trials have all taken place using Temporary Danger Areas (TDAs) which restrict other airspace user activity and are not sustainable for commercial operations. The objective of this project is therefore to develop a trial airspace test zone based on a more permanent, less restrictive form of airspace, where future sustainable aviation technology and use cases can be demonstrated.

HIAL’s Pat Nolan has been working with Egis’ Richard Derrett-Smith and Stewart Wallace on developing the Trial Orkney Test Zone or TOTZ. This pioneering project is part of the Sustainable Aviation Test Environment (SATE) and is part funded by the UK government through the UK Future Flight Challenge programme. HIAL is both an airport operator (with 11 regional airports) and an Air Navigation Service Provider, and so it plays a vital role in supporting essential lifeline services, connectivity and socio-economic development within the rural and island communities. Pat says: “Our aim is to establish the UK’s first low carbon sustainable aviation test centre, including a dedicated airspace test zone, to be located at a commercial airport.” Using Kirkwall Airport as its base, the test zone has been designed to minimise the impact on Kirkwall airport’s operations. Kirkwall is a licensed commercial airport that provides services for approximately 12,000 aircraft movements carrying 130,000 passengers per year, the majority of which by Loganair the airport’s principal operator. Kirkwall airport, which provides an aerodrome and procedural approach service, is located in Class G airspace and has a suite of both conventional and RNP instrument approach procedures.

Using Kirkwall Airport as its base, the test zone has been designed to minimise the impact on Kirkwall airport’s operations. Kirkwall is a licensed commercial airport that provides services for approximately 12,000 aircraft movements carrying 130,000 passengers per year, the majority of which by Loganair the airport’s principal operator. Kirkwall airport, which provides an aerodrome and procedural approach service, is located in Class G airspace and has a suite of both conventional and RNP instrument approach procedures.

Richard says: “From the outset our approach has been to align our solution with the UK CAA’s vision for modernising airspace and with the recently released Future of Flight Action Plan.”
The TOTZ extends northwards over the Orkney archipelago and is subdivided into 5 subzones, such that only those zones required to support a particular trial or operational activity need be activated, thereby leaving the other TOTZ subzones available to other aircraft. This is consistent with the CAA’s Flexible Use of Airspace policy to ensure equitable access to airspace for all airspace users. The TOTZ airspace design ensures separation from Kirkwall’s instrument approach procedures which will minimise disruption to Kirkwall’s scheduled commercial flights.
Richard continues: “We have included an emergency buffer zone around the TOTZ to ensure that the drone’s Detect and Avoid (DAA) system, air traffic control and/or the drone pilot can take appropriate action to neutralise any potential conflict if a non-participating aircraft unexpectedly enters the emergency buffer zone.”


Airspace design: Trial Orkney Test Zone (TOTZ)

Designed to minimise impact on Kirkwall Airport operations

Of course, airspace is not the only driver in terms of managing risk. The HIAL and Egis team also considered the critical role of air traffic services in providing effective oversight to the TOTZ operations. Communications, navigation and surveillance technology proportional to the scale and complexity of airspace users is also part of the solution, and, coupled with the technology on the drone, will need to integrate effectively with the airspace design and air traffic service delivery to minimise operational risk and support sustainable commercial operations at scale.

Concludes Pat: “The SATE project and HIAL are confident that the TOTZ trial will be accepted by the UK CAA into its Regulatory Sandbox (Temporary Reserved Area) programme, enabling us to deliver the TOTZ airspace trial in the Orkneys based on integrated operations in unsegregated airspace from Kirkwall airport. The outputs from the TOTZ trial will provide HIAL with the data and experience to establish a more permanent trial airspace known as the Orkney Trial Zone (OTZ). The OTZ will provide the blueprint for HIAL to implement a similar hub and spoke airspace model across the HIAL airport estate.”

Adds Richard: “We see the TOTZ trial as vital first steps towards achieving integrated RPAS operations in unsegregated airspace, which is a European, if not global aim these days. It will also generate some key learning points for uncrewed aerial system operators, who need to understand how they can work from a licensed commercial airport.”

Read more about about our work on drone integration in the UK. For more information about the Trial Orkney Test Zone (TOTZ), contact Richard Derrett-Smith, Director Egis.

Richard Derret-Smith

Associate Director, Aviation

Feature image credit: Windracers

Egis is a member of ARPAS-UK.

SAM IS ....
ARPAS-UK AGM & Annual Conference

What a day!

The ARPAS-UK AGM & Annual Conference was held on a glorious spring day. We had a strong turnout and great speakers. BT’s Headquarters provided an excellent venue, and we thank them for allowing us to be there.

Networking is an important part of such events and the ARPAS-UK Team had factored this in to ensure that Members and speakers had sufficient time to (re)connect before the AGM, during lunch, the afternoon break and after the Annual Conference.

In the AGM, two new directors were elected: Sarah Lay and David Thurston. We are delighted to welcome them on board. In addition, Graham Brown and Anne-Lise Scaillierez both stepped down as Directors per rotation and were re-elected. In all cases, the voting was unanimously positive. A record of these resolutions has been made.

The Annual Conference:

The presentations are best viewed as videos and can be found below (click on the Presentation title). We thank the speakers for their time and expertise. We much appreciate their participation in our event.

The ARPAS-UK Kick Off Presentation

  • Graham Brown, Chair of ARPAS-UK
  • Anne-Lise Scaillierez, CEO of ARPAS-UK
  • Elena Major, Ops & Membership ARPAS-UK

The Future of Flight Action Plan Update

  • Jenny Ward, Deputy Director for the Future of Aviation at the Department of Transport (DfT)

Update with the CAA

  • Kevin Woolsey, Head of RPAS Systems at the Civil Aviation Authority (CAA)
  • Callum Holland, RPAS Sector Lead: Application at the CAA

Mobile Network as BVLOS Enabler

  • Dave Pankhurst, Director of Drones BT
  • Ed Hunter, Senior Product Manager: Drone Solutions at BT

OSC Success Stories: Quantification of ground risk for Overflight; flying 30 km BVLOS

  • Rowley Cory-Wright, Director at HEXCAM

Members’ Panel:  sharing their stories and operational experiences

  • Andrew Richman, project Manager in Geomatics at the Environment Agency
  • Adrian Wilkinson, Managing Director at Land & Minerals Consulting, drone operator and chartered geologist.
  • Rebecca Jones, CEO, Iprosurv, RAE 
  • Rupert Dent, Managing Director, Bridgeway Aerial, Operator

Photos of the day

SAM IS ....
NATMAC 95: 11 April 2024

Rupert Dent attended on behalf of ARPAS-UK to ensure the Drone Industry is kept up to date and has an opportunity for their voice and opinion to be hear.

Presentations included:

  • Airspace Modernisation Delivery Team on Electronic Conspicuity, Future of Flight Brief, Atypical Airspace & Manchester Low Level Route Update
  • Introduction to the Integration Sandbox
  • Airspace Change Organising Group (ACOG) Briefing
  • ICAO FIS alignment implementation
  • 2023 AMS Progress Report

12 April 2024

SAM IS ....
CAA launches new PDRA01 Operations Manual Template, plus updates to CAP 722H & CAP 2606

The CAA has now changed how you apply for a PDRA01.

They no longer ask you to upload your Operations Manual when you apply or reapply. Instead, they ask you to confirm that you have, and will maintain, a valid manual that meets the requirements. You may be selected for an audit at any time.

These changes are part of their activities to transform the operational authorisation process for Remotely Piloted Aircraft Systems (RPAS) in the Specific Category.

Changes that come as part of the overhaul include:
⏱️ Application process cut from 6 weeks to 24hrs
💰 Single fee of £234 applies to all applications and reapplications
📈 A new and improved reapplication scheme

Note: Existing PDRA01 Operational Authorisations remain unaffected and will continue to be valid until their expiration date.

The CAA has published an update to CAP 722H (Pre-defined Risk Assessment requirements, guidance and policy) and CAP 2606 (template Operations Manual to support PDRA-01).

CAP 722H has been updated following the launch of the PDRA digital online system, and CAP 2606 has been updated to clarify certain operational requirements.

Both of these documents can be found on their website:
•    CAP 722H
•    CAP 2606

What is PDRA01?

The Pre-Defined Risk Assessment 01 (PDRA01) is the simplest type of Operational Authorisation to apply for. It gives you authorisation to fly unmanned aircraft (UA) below 25kg within visual line of sight (VLOS) at residential, commercial, industrial, and recreational areas.

Examples of the reasons people use PDRA01 include:

  • inspecting roofs
  • taking photos of buildings
  • surveying recreational sites

PDRA01 is the only PDRA that’s currently available. The Civil Aviation Authority may add more in the future.

SAM IS ....
Pioneering simulations pave the way for routine drone flights in the UK

The prospect of remotely piloted drones operating in and out of some of the UK’s busiest airports has taken a step closer to reality following a series of pioneering simulations by the air traffic management service, NATS.

The simulations, run at NATS’ head office in Hampshire, demonstrated how drones could be seamlessly integrated alongside other air traffic at a busy airport. This included drone operators filing flight plans, flying in and out of the airport and being safely deconflicted with other aircraft.

The leading work forms part of Project CAELUS, a UKRI industry collaboration of 16 partners including AGS Airports, University of Strathclyde, NATS and NHS Scotland, aiming to use drones to transport essential medical supplies throughout Scotland.

Drone-D0952a_Caelus_08032024

The project’s first test flight occurred at Glasgow Airport last year, with a drone flying to the nearby NHS Golden Jubilee hospital. The concept development and simulation work NATS has led on is essential to understanding how that one-off flight could be safely scaled up to include dozens of drones flying ‘Beyond Visual Line of Sight’ and delivering medicines and blood tests to patients across Scotland and potentially beyond.

The airspace integration was overseen by a new Airspace Manager function using new technology developed by NATS. As part of this proposed ‘concept of operations,’ direct voice communication between a drone operator and air traffic control would only be required by exception – including the kind of emergency scenario demonstrated during the simulations.

Richard Ellis, NATS New Airspace Users Director, said: “Everything we’re doing is striving towards enabling the seamless, safe integration of drones and other new airspace users into our skies. There is a lot of work still to do, including the development and approval of new technology and regulations, but I believe what we and our Project CAELUS partners are doing will help support that process and is taking us a step closer to an exciting future.”

Fiona Smith, AGS Airports Group Head of Aerodrome Strategy and Project CAELUS Director, said: “We have continued to see some valuable collaboration and innovation across Project CAELUS and this latest work led by NATS truly demonstrates our ambition to forge a new path.”

“Our first live flight trial last year was incredibly important and demonstrated a means of integrating drones into an airport environment.”

“This year, we look forward to showcasing many more demonstrations including a ramped up flying programme across Scotland and we are delighted to kick start that programme with this exciting NATS showcase”.

Hazel Dempsey, Caelus National Programme Manager from NHS Grampian added: “Exploring how drone technology could be usefully used as a way of delivering care to people who live in urban, remote, rural and island locations, is edging ever-closer to a reality.”

Project Caelus is a Future Flight Challenge programme jointly funded by UK Research and Innovation. Further test flights are planned for later this year.

SAM IS ....
ARPAS-UK supports the introduction of Atypical Air Environments to unlock BVLOS opportunities.

Let’s each respond to the CAA’s consultation by April 2.

ARPAS-UK supports the introduction of the Atypical Air Environment policy, as an incremental step to facilitate BVLOS operations in lower risk environment, where no another aircraft is expected to be, for example just above assets that are inspected. These will already unlock a lot of economic value, and help the industry accumulate experience and flying hours in BVLOS.

We will respond to the consultation as an organisation. If you would like to get involved in our response, do let us know by emailing us at [email protected], and join either or both REG SIG and/or BVLOS SIG.

To understand the proposed policy, you may want to listen to the podcast by Callum Holland from the CAA’s Future Safety and Innovation Team. Then please respond to the consultation as well by April 2. Compared to other consultations, it is pretty straight forward.

19 March 2024

SAM IS ....
DfT published the Future of Flight Action Plan: Objective of BVLOS UAS operations in integrated airspace at scale in 2027

ARPAS-UK was one of the stakeholders involved in the co-design of the Future of Flight Action Plan and we support it. We have a collective roadmap that will help us shape the industry and take it to the next stage. It is the result of reasonable compromise among the parties, and now it is up to all of us to help deliver, step-by-step, in an iterative process.

Quite a lot of attention is focussed on the passenger carrying aircraft, also referred to as Advanced Air Mobility. The first milestone will be the demonstration for the first time in the UK of an eVTOL, piloted, in 2026.

Anne-Lise Scaillierez, CEO of ARPAS-UK, was interviewed on Sky News on the 18th, and a few questions were raised on that topic, as well as the need for vertiports.

You can access ARPAS-UK CEO’s interview on Sky News Here.

Now, the most important next step from our perspective is to deliver the first incremental milestones. For UAS, these are:

  • 2024: Demonstration o BVLOS UAS operations in non-segregated airspace, as part of the CAA sandbox programme and the Future of Flight programme
  • 2027: Routine BVLOS UAS operations in integrated airspace at scale.

In the interim, we support the introduction of the Atypical Air Environment policy. It is an incremental step to facilitate BVLOS operations in lower risk environment, where no another aircraft is expected to be, for example just above assets that are inspected. These will already unlock a lot of economic value, and help the industry accumulate experience and flying hours in BVLOS.

You can access The DfT publication here.

SAM IS ....
Our response to the CAA’s Remote Pilot Competence Consultation due 14 March 2024

We welcome the concept of having incremental levels of Remote Pilot Competence as more complex operations become routine.

The definition of BVLOS is not included. It would be useful to do so.

# RPC Level 1:

There is little/no? difference in the privileges with the GVC. Therefore, it should just be acknowledged that it would eventually replace the GVC. RAEs will probably stop offering the GVC if/when RPC L1 is in force.

Having said that, it is essential that current GVC holders do not have to redo (and pay) for training to get a RPC Level 1.For example, it could be valid until the same revalidation period as RPC L1. It might be the rationale for the comments collected during the initial consultation that the GVC should remain in parallel to RPC L1 even though there is little difference between them.

Also, a number of OSC holders today have permission to fly BVLOS with visual mitigation. Remote pilots have GVCs, and have accumulated experience to support that permission. The RPC L1 mentions BVLOS is prohibited, which should be amended so that BVLOS with visual mitigation airspace observers ex EVLOS etc are part of the privileges of RPC L1 holders.

RPC Level 1 should not enter into force on its own, it would be better if it enters into force with the RPC L2 Atypical for example, else the industry could consider it as regulatory changes and cost of compliance with no benefit (same privilege as GVC).

RPC Level 1 Advanced with additional privileges wrt ground risk or other practical market needs?

The levels are structured around incremental air risk, and does not mention ground risk. Yet, depending on the UK SORA version, the market could need training specific to reduced distances from uninvolved people, or flying in higher density areas, if it is not covered in RPC Level 1.There could be other training curriculum needs that deliver market value before considering the big jump to RPC L3, for example in the survey, inspection, search and rescue and mid-range delivery spaces if they are not adequately covered by L1 and/or L2.

# RPC Level 2:

The privilege is to fly in ARC-a, i.e. in Atypical Air Environment. You should specify “BVLOS” in ARC-a.

It would make sense to review the training curriculum with the final AAE policy currently under consultation so that both go hand in hand.

The entry point should be holders of RPC L1 and/or GVC holders.

# Collecting feedback from industry on Level 1 and Level 2: DISCO and RAE workshops

The feedback we received is that the L1 and L2 training curriculum are going in the right direction, but it would be more efficient to get industry feedback either through DISCO meetings or workshops with RAEs.

We actually strongly recommend an RAE workshop to try to work the syllabus through, using the wealth of experience available between the RAEs. It would be less formal and time-consuming than a written consultation, and would facilitate discussions. We understand that some parties selected for the DISCO project were contacted, others not.

If not via DISCO, why not via an equivalent of the FAA’s ARC Committee?

# Revalidation, renewals

We recommend that the specifics of revalidation are mandated across all RAEs and consistent, rather than each RAE making a case-by-case assessment. So that the revalidation has the same value, and an RP can change RAE over his/her career.

# Simulation

The specifics around simulation should be detailed, as this is new to the industry (vs GVC).

# RPC Level 3

The privilege is to fly BVLOS in ARC-b.

Until the UK SORA is adopted, it can be premature to launch a training programme since we don’t know what the actual regulatory framework will be. We don’t know the requirements for sharing airspace (like the specifics of EC mandated or not, FIS provision requirements etc).

RPC L3 curriculum should respond to the question: what  additional RP training is required to fly in non segregated airspace ARC-b (vs L2 atypical) where there will be other airspace users? in BVLOS with a fully automated system, with different ways to identify and deal with abnormal situations ( deep mechanical and technical engineering is probably of little use to the RP when dealing with an emergency situation), flying sub 120m, with different ways and technologies to perform Detect and Avoid…. and not assuming  the RP is actually manually piloting, detecting with his/her own eyes and ears, flying at higher altitudes in the clouds etc.

These simple questions do not appear to be the driver in the curriculum described in Appendix B . Instead, it seems to be a copy-paste from a PPL documentation with a serious amount of completely irrelevant items, whereas the key questions do not appear to be well answered.

We recommend scrapping Appendix B for L3+ altogether, and start instead with a relevant basis. We are not aware of a BVLOS training programme by other aviation authorities, but there are internal training courses by RAEs, operators, and OEMs including for military / large platform OEMs. The BVLOS Sandbox participants likely have internal training programmes, or have a good view of what they expect from the RP. Why not leverage those as a starting point?

The number of hours of practical training (55 hours) should be justified through evidence, and ensure the source is not a copy-paste from a PPL requirement.

Starting level 3, there should be mandatory type-specific training delivered by the OEM or an entity designated by it, or an RAE or an RAE-F that would replace the AGK curriculum section in Appendix B.

Starting level 3, you could/should consider a standard training curriculum for the Operator’s Accountable Manager, and the Training Instructor – proportionate to the mission at hand. The point would not be to request drone BVLOS operators to put in place a heavy structures like airlines, but to standardize the training of those 2 key roles.

# RPC Level 4

What if the most important question becomes the RP competency to manage/oversee multiple fully-automated drones, with a high level of safety, considering in a 1:30 ratio – rather than IFR rules?

Are we sure we need a 4th level, and/or do we have a good view of what additional training would be required vs L3 at this stage? Do we need to define all levels at once? May the most practical is to start by Atypical PRC L2 in conjunction with the AAE policy first, learn from it then move to the next level.