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Tips: CAP2606 PDRA01 Ops Manual template is a proposed AMC, is it mandatory or optional?

Source: written exchange with CAA representative, July 2024

CAP2606 is a suggested format for a PDRA01 Operations Manual Template, but optional, the CAA do suggest operators use the provided template as it provides Operators with an easy-to-use method of complying with the regulations set out in CAP722H.

Q: Can operators continue to use and update their existing PDRA01 Operations Manual, reflecting as need be the CAP2606 recommendations?

Operators can continue to use and update their existing Operations Manual as long as they continue to fulfil their obligations as per UK Reg (EU) 2019/947 UAS.SPEC.050.

Note from ARPAS-UK: CAP2606 Ops Manual template is a proposed means of compliance to the operator’s obligation as per UK Reg (EU) 2019/947 UAS.SPEC.050 “Responsibilities of the UAS operator”. It is comprehensive, and in a way takes the Operator’s professionalism to an “OSC-ready” level since the underlying assumption is the maximum risk level under PDRA01. Many operators likely operate at the other end of the PDRA01 spectrum, where simpler Operations Manual and checklists could be sufficient.

Q: Will the CAA issue a guidance document to highlight the required info for those who will keep their existing Vol1?

Currently the CAA does not intend to issue further guidance for ad-hoc Operation Manual types, instead recommending that Operators move to the template suggested in CAP2606.

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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.

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New Digital PDRA01 Application Tool Live in March!

The CAA aims to launch the new Digital PDRA01 Application Tool at the beginning of March.  The aim is to simplify the PDRA01 application and renewal process, and to make it online.The key expected benefit is that applying for an OA will be made easy and quick. The review and approval process will also be automated and quicker.

The philosophy is that the Operator will make a number of declarations of Compliance to get the OA, which will formalise his/her commitment to follow the regulatory requirements and his/her legal responsibility. That responsibility has always existed, but the oversight regime of it is evolving.

Each and every application will no longer be individually renewed, at least not in detail, because the operator will have ticked the many required boxes and committed to compliance. The CAA oversight teams will focus more on conducting adhoc audits – a little but like tax returns and tax oversight regime.

A template PDRA01 Operations Manual will be provided, which should clarify what’s required to be compliant in practice as well.

Will it change the heart of PDRA01, meaning its obligations and privileges? Or the interpretation of them? Like the issue of distance from uninvolved persons? It is unclear at this stage, and we’ll continue engagement on that point.

Below are key extracts of CAA communication to drone operators due to renew soon, for transparency.

“This marks the first milestone in the Digitisting Specific Category Operations (DiSCO) project that aims to transform the Operational Authorisation process for Remotely Piloted Aircraft Systems (RPAS) in the Specific Category.  

  Key features of the new PDRA01 Application Tool:  

The new PDRA01 Application Tool aims to make it simpler and quicker for you to apply for a PDRA01 based Operational Authorisation. Key features include:  

  • A streamlined application process: PDRA01 applications will be declarative in nature, reducing the amount of information required to be provided to us at point of application. 
  • Faster authorisation: Authorisation outcomes will be provided within 24 hours.   
  • Improved guidance and support: We’ve simplified the guidance on the CAA website to help you understand what you can do under a PDRA01, the requirements you need to meet and how to apply. We will also provide a new PDRA01 Operations Manual template that will help you to ensure you are compliant.
  • Self-service access: Once applications are approved applicants are notified by email.PDRA01 Operational Authorisation certificates will then be available to view and download at any time in My Registration.0  
  • Oversight regime: Post-application, operators will continue to be subject to compliance oversight during the 12-month period over which their authorisation is valid, as part of our oversight regime. This will involve being asked to provide an up-to-date Operations Manual, along with evidence that the processes within it are being followed, such as logbooks.  

What the launch means for operators: 

When we launch the new PDRA01 Application Tool, we will only accept PDRA01 applications made via the new process. The existing PDRA01 application form will no longer be in use.  

If you have started an application on the current PDRA01 application form (which you can do from 3 months before your expiry date), you will be able to continue and submit this application for 30 days after the system goes live. After this point, you will need to start a new application on the new PDRA01 Application Tool.  

You will be able to renew your authorisation using the new tool from 28 days before it expires. Please note that you will need to have a valid Operator ID before you can start the application process.    

Charges 

The fee you pay for Operational Authorisations pays for both the initial, and ongoing regulation of the RPAS industry, including assessing applications, ongoing oversight and introducing new and improved technology such as the new PDRA01 Application Tool and the associated upkeep of the new technology system (and broader DiSCO programme).  

The fee for applications made on the new PDRA01 Application Tool will be £290 for applications made on or before 31st March 2024, and £314 for applications made on or after 1st April 2024 (as per the 2024/25 Scheme of Charges). There will only be one flat fee going forwards to streamline and simplify the process. 

Please visit the CAA website for further information on charges. 

How we’ll let you know when the tool is live  

We’re aiming to launch the tool at the beginning of March. We’ll email you again when the tool is live and ready to use. You will also be some of the first users of the new process, so there will be increased support available for you, should you have any issues.  “

A-L Scaillierez