Find Your Way Around Your Operations Manual
The end of 2020 brought more than another lockdown. It brought the biggest raft of legislative changes we’ve ever seen in the industry. These will reverberate for years to come…but right now you don’t care. You just want to update your Ops Manual.
You can do this yourself.
Here are the things to look for if changing your manual from the end of December 2020. Be aware that this document isn’t necessarily kept up-to-date and it is your responsibility to get your manual updated correctly. Failure to do so may indicate a lack of understanding of your own manual and leave you vulnerable in the event of a CAA audit. Don’t say you haven’t been warned. Sub-contracting this element of your business and not understanding your manual is your responsibility and yours only.
If you are in any doubt as to what should be in your manual, check out CAP722A which provides the CAA template.
Step 1 Remove inaccuracies
Your OM may have slipped through last year with reference to CAP722 Appendix B. This is an old reference that describes the template against which your manual was produced. Now, this may be a true statement but the document it is based on is obsolete. Best advice is to remove the statement entirely.
As of mid January 2021, the ECCAIRS reporting portal has also changed its location and the CAA will be looking to ensure you have kept up with this.
The ECCAIRS2 overview can now be found at https://aviationreporting.eu. Not a huge change from the previous site name but enough! The actual form is found at https://e2.aviationreporting.eu/reporting Change the link in your manual and show that you know it is the ECCAIRS2 portal you are pointing to.
Step 2 Amendment Record
Whatever you change, make a note of it in your amendment record. This will be near the beginning of your manual. The date of amendments and amendment number should match those on the front cover.
Top tip: Remove issue numbers and dates from headers and footers of your documents. They just leave you with more places to update every time. Golden rule with key information is to have it in the correct place only…and only once to save you having to catch it at multiple locations
Step 3 Update the Document Reference Table
Fun fact. CAP722A does not require a document reference table. However, the CAA likes to see it to confirm very quickly that you understand the latest versions of the legislation you are working to.
I won’t give the document dates and issue numbers here because they are subject to constant change, especially at the moment.
But what you do here is input the current document name (e.g. CAA CAP393) into a browser search and click on the CAA link that comes up. Here’s an example:
Click on the one you like the look of and you will be able to see the version and date. Some of the links may take you directly into the document pdf. It this is the case then you can get the version and date directly from the beginning of the document.
Be careful with CAP393. This is not the Air Navigation Order itself. The ANO is an externally generated document (by parliament). So when the CAA take it into their document system they give it a CAP “wrapper”. The difference this makes is that sometimes the CAP will have an issue date a week or so after the ANO has been issued. So be careful. I find it easier to reference the CAPs and maintain this as a policy throughout.
It’s a good idea to copy the document web address from your browser and create a link within your document. This will help you access the source document when you need to.
So just check that the documents haven’t been updated since your last review. To be honest, they shouldn’t because you are subscribed to SkyWise and keep these things updated throughout the year, don’t you?
If they have been updated, then input the version number and date in the relevant columns.
Step 4 What if you fly FPV?
You may have reference to FPV flying (or the conditions under which the RP can stare for a whole flight at his/her device). If you do, you will be referencing ORS4 1294 or ORS4 1297.
1294 is now covered within the UAS regulations (within CAP2013) and 1297 is covered by general exemption ORS4 1449. Essentially, maintain the description of your mitigations but you can lose the references to the ORS4 document.
Step 5 Add to your Reference Table
Now updated to version 3 dated 22nd January 2021, the aviation reporting portal is no longer the ECCAIRS system. No, it’s now the ECCAIRS 2 system. CAP1469 will guide you there and provides some nice, detailed instructions on the use of the portal.
This was launched at issue 1 on 17/12/2020. It is designed to outline the proposed changes to the Air Navigation Order as it reflects the EASA-based changes. Referencing the ANO (CAP393) without referencing this will get your OM rejected. Note: By the time you read this, the ANO itself may have been amended. If it has then don’t bother referring to CAP2013..but check the date and issue of your CAP393 reference.
UAS Implementing Regulation (EU) 2019/ 947 Consolidated Text
You may not be familiar with this one but you probably need to understand where it fits in. It contains all the rules, clearance distances etc. that are contained within the new rule set. These have been effectively described in CAP722. But CAP722 is a guidance document. This one is the law (or at least the parts that will be referenced in the revised ANO will be the law).
Launched on 16/10/2020, this fascinating document is a glossary of acronyms and definitions that the CAA would like you to use in your manuals. Please don’t disappoint them. Reference this document and move on to the next step.
Step 6 Abbreviations and Definitions
You know how the CAA is for TLAs (Three Letter Acronyms)? Well, as mentioned above CAP722D is full of ‘em. There is some inconsistency in approach depending on who assesses your OM, but some have been sent back because they have abbreviations and definitions at the beginning of the document that don’t actually get used anywhere else. This is pretty much a waste of ink and paper. It is best to remove any that you don’t use – just do a CTRL “F” and see if you get more than one result.
Then go through your existing abbreviations and check that they match the preferred CAA version. An example is that SUA – Small Unmanned Aircraft, which used to be defined in the ANO no less, is no longer de rigeur. Instead you should be using UA – Unmanned Aircraft (if you are referring to the drone itself) or UAS – Unmanned Aircraft System (if you are referring to the aircraft system plus groundstation.
Sorry, did I say Groundstation? How foolish. A GCS – Ground Control Station is now to be referenced as a CU – Command Unit. And you no longer require permission for commercial operations, so you may want to change PfCO to OA (for Operational Authorisation).
People, Vehicles Vessels and Structures is another commonly used phrase. Now though, there is an emphasis on Uninvolved Persons.
I’m not going to list them here, but you need to cross reference your current list and change out (throughout your document) and that need changing. It’s a simple but painstaking process so go steadily and logically.
Step 7 Safety Statements
You will have some general safety statements near the start of your manual. Have you ever read them? Read them again. You will want to reflect the change in emphasis from the protection of People, Vehicles Vessels and Structures to the protection of uninvolved persons while bearing in mind your responsibility towards vehicles, vessels and structures while flying, even if they are unoccupied.
See CAP 722 version 8 sections 2.1.3 and 18.104.22.168 for help on this.
Step 8 Check out ORS4 1449
You should be aware of this exemption already. If not, make yourself aware as it contains some of the easements that previously you would have required an OSC to work to.
Run through the exemption and cross check it against your operations sections. Depending on how your operations are described. If relevant you may be wanting to change the sections around clearances for take-off and landing to ensure your planning focuses on uninvolved persons while ensuring you still protect the safety of vehicles, vessels, structures (and their occupants).
Step 9 Check out CAP2013 (or the revised CAP393)
This document contains the changes to CAP393. There have always been two approaches to the ANO in Ops Manuals. One is to copy the relevant articles in full into your document. One is to just reference the relevant articles in the appropriate parts of your manual. Whichever you do, you need to recognise that the structure around the drone rules have changed.
Article 94 is stripped down to just sections 94A and 94B and just covers flights around aerodromes and should be referenced (or copied and pasted) into the relevant section to replace what you have. Delete references to any other existing article 94 sections (C to G) you may have.
Note that if your manual references the ability to fly above 400ft within an FRZ with the permission of the ATCU then this needs to be removed. CAP2031 Article 94 notes (page 3) clarifies this.
References to Article 95 should be removed as its requirements are superseded by the new UAS regulations.
It is worth referencing articles 240 and 241 and perhaps even including them in full to show you are aware of their importance.
Now, for the balance, I admit I don’t know what the CAA is seeking and they don’t appear to be very forthcoming with advice even after two weeks and months of planning. Articles 265A to 265F all relate to the offences and penalties. My feeling is that it should be sufficient just to reference these in an appendix. Currently there is no “Offences and Penalties” section contained in the templates document (CAP722A). Here is what I have done but we won’t know until the CAA have assessed a range of Ops Manuals what they are prepared to accept.
|265A||Offences: Contravention of Commission Implementing Regulation (EU) 2019/947 on the rules and procedures for the operation of unmanned aircraft – UAS operator|
|265B||Offences: Contravention of Commission Implementing Regulation (EU) 2019/947 on the rules and procedures for the operation of unmanned aircraft – remote pilot|
|265D||Minimum age requirements|
|257||CAA’s power to prevent aircraft flying|
Step 10 Compliance Statement
The CAA wants to see a compliance statement. This will want to be as close as possible to the top of the document. Mine has gone in as part of the statement by the Accountable Manager. The statement it wants includes the mention of PDRA01 in respect of the OA they issue. It’s a complex point but until you renew you don’t have a PDRA01 OA. But I would err on the side of including the full statement. After all, your Standard Permission, coupled with the ORS4 1449 general exemption effectively equals a PDRA01.
Here is the statement:
“All Operations will be carried out in accordance with the issued Operational Authorisation PDRA01 and abide by the requirements of AN02016 – 2020 Amendment and UAS Implementing Regulation 2019/947 (as retained in UK Law).”
Step 11 Finally
Check you’ve done everything above. This is aviation so use the checklist below!
I offer NO GUARANTEE that any manual updated to these instructions will be accepted by the CAA. It’s your manual and you need to understand not only your procedures but the law surrounding them. Do that and you’re halfway there!
However, if you have found this useful, I would be delighted to receive your comments. Is it easy to use? A pain in the arse? Impossible to understand? Email me at email@example.com and let me know…I really don’t bite.
If you need some tricky work doing that even an A2CofC can’t help you with and you’re in the South of the UK then hit me up. I can fly legally at heights you won’t get away with even with some of the relaxations. And I can operate proper sized drones in built up areas at very reduced clearances too. Same email address applies. I can even help you towards similar exemptions!