This blog will be out of date for any renewal beyond 31st January 2023
Please note that although this page desperately needs an update, this is currently on hold. On 7th December 2022, the CAA released their CAP722H document, which was supposed to lay out the operational conditions for a PDRA01 permission. Unfortunately, this document is full of contradictions and is, at the time of review, unusable. Click here for an Eyeup report on the CAA’s first attempt on this document. To their credit, the CAA has listened and they are currently reviewing the document internally before (apparently) sending to key stakeholders for assessment. They have undertaken to release an updated version (in time for operators to update their manuals for renewal before the deadline of 31st January 2023. We live in hope.
As soon as CAP722H version X is released, I will carry out my own assessment and update this page accordingly or release a new blog (it’ll be nice to maintain a history on the blog page).
In the meantime, and based only on a hunch, because official guidance is non-existent I’m afraid, I would leave reference to CAP722H Version 1 (current at 28/12/2022) out of your regulations reference table. You may find your application is put on hold but my concern is that by referencing the document you may be legally held to its content, some of which may contradict your operational procedures. This is a mess of the CAA’s making and I’m hoping it is cleared up quickly.
I will also become a capitalist pig and start asking for donations in exchange for this hitherto “free” service. No obligation, but maintaining this stuff does take time and keeps me away from my family. If anybody is feeling generous or wants to pay forward then feel free to follow this Buymeacoffee link.
The version of this page created in December 2020 has been, by far, the most popular Eyeup blog of 2021. This is sort of predictable because I know just how many operators hate and fear anything to do with updating their operations manual in equal measure. If you need the old blog version for some strange reason you’ll find it here.
I have a couple of other pages which may help you develop or improve your current processes:
Structure of your Documents
The big EASA-based changes have worked their way through the system like a Saturday night curry through a heavy drinker. So, what needs to be reviewed in manuals now?
The headline is that amendments from 11:00pm on Dec 31st 2021 should be a whole lot easier than last year. I’ve dropped it from an eleven to a five-stage process!
Plus ca change
Some things never change. Unfortunately, UAS legislation isn’t one of those things. There will always be a need to keep an eye on legislative changes coming through as these may impact your operations (though this is rare). What they do impact is your reference table as the CAA always wants you to prove you are up-to-date on changes. 2021 saw a large number of changes as the new legislation was introduced across a range of CAP documents. For example, the latest change in 2021 appears to have been a tidying up of CAP1789A on 14th December – did you pick up on that one?
Before you pile into the process below, I would recommend you check out my other blog on Drone Operations Manuals – Tips and Tricks. These can lead to a general improvement in your overall manual look and feel.
You can update your manual yourself
The information below assumes that either you or the CAA have picked up on various inaccuracies that they have been trying to weed out over the years. Occasionally they will miss stuff and if you haven’t picked up on it you will get your renewal put on hold. Don’t stress about this, just make the change the CAA is requesting and ping back an updated version of your manual. I have never known them charge the £124 “fine” for corrections where an operator has made an effort to update their document.
Be aware that this blog 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 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 2 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.
What you need to do here is input the current document name (e.g. CAA CAP1789A) into a browser search and click on the CAA link that comes up. Here’s an example:
The link you want should be pretty obvious so click on it. It should take you to a page like this where the latest version and date will be obvious. These should be used in your reference table.
Here’s another tip. If the version has changed, click into the document and take a look at the changes. Who knows, they may directly impact your operations. Document amendments will generally be outlined in the first few pages of the document.
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.
Step 3 Review your Reference Table
Here are the documents I reference in my standard manual. They may differ from yours and you may or may not want to add to your current list. It’s your manual to manage but some of these may be useful to you…or not!
A bit of a revision is needed if you refer to the old CAP2038A00 to locate the Air Navigation Order 2016. On 29th April 2022 the CAA removed the old CAP and replaced it with a link to the Air Navigation Order 2016 as amended by the Air Navigation (Amendment) Order 2022. The latest amendments don’t appear to impact UAS operations and are concentrated on airworthiness and interpretation of EU regulations.
Until advised otherwise, I will be referring to it as the Air Navigation Order 2016 (April 2022 Amendment) dated 13th April 2022. Keep an eye on this date yourself because I won’t guarantee to keep it updated in this document.
CAP1789A UAS Implementing Regulation (EU) 2019/ 947 Consolidated Text
UAS Regulation EU 2019/947 Consolidated Regulation, Acceptable Means of Compliance, Guidance Material and Certification Specifications to UK Regulation (EU) 2019/947 (as amended)
CAP722 UAS Operations in UK Airspace – Guidance
CAP1496 New Aviation Reporting Portal
Depending on your RAE, you may have reference to CAP382 Occurrence reporting Scheme. Feel free to leave this in. However, if you click through to CAP1496 you will find in paragraph 2 a link to the CAA CAP382 occurrence reporting page, so CAP1496 covers all the bases.
CAP722D UAS Operations in UK Airspace – Master Glossary and Abbreviations
This one, launched on 16/10/2020 (updated since so get the right version), is a glossary of acronyms and definitions that the CAA would like you to use in your manuals. Please don’t disappoint them.
Finally, and as referenced in my opening “Edit” paragraphs, we must cover the subject of CAP722H. You may choose to add this to your reference table. The issue is that version 1 will almost certainly conflict in several potentially critical ways with the operational procedures in your Operations Manual. The CAA may put an application on hold and insist that you reference it. I would counter with the fact that you know the document is invalid and under review. Use my blog on the subject as evidence if you like. If they insist, then as a business, you have a decision to make. With luck, the situation won’t last beyond a few weeks but the regulator is putting operators in a very uncomfortable position at the moment.
Step 4 Check out the Air Navigation Order
The latest home of the ANO is given in Step 3 above. The CAA wants to be sure you are aware of the latest changes to this document. If your manual doesn’t currently refer to Article 94BA then the part of your manual covering permissions to fly needs to be looked at. 94BA covers permissions required to fly near a “space site”. You almost certainly won’t have one of these anywhere near you, but you need to include it in your manual…just in case!
Step 5 Compliance Statement
All Operations Manuals submitted with applications are required to be updated to refer to the new UAS regulations. This is so that the CAA knows the operator is familiar with the new regulations.
They suggest that a simple statement could be included within the manual such as:
‘All Operations will be carried out in accordance with, and abide by the requirements of ANO 2016, as amended, and Regulation (EU) 2019/947 as retained (and amended in UK domestic law) under the European Union (Withdrawal) Act 2018 – (The UAS Implementing Regulation, or ‘UAS IR’)’
Mine has gone in as part of the statement by the Accountable Manager.
Step 6 Helicopter Landing Sites
On 21st June 2022 the CAA issued a request that a NOTAM be raised to warn of UA activities “in the vicinity of a Helicopter Landing Site (HLS). The notice does not define exactly what constitutes a HLS and HLS is not defined to us within the current (at 21st June 2022) issue of CAP722D – the master glossary. Shame on you CAA.
So this is fresh and may be wrong but here is my approach.
I have added an abbreviation of HLS for Helicopter Landing Site and defined it as any helicopter operating site indicated on the Altitude Angel UAS DroneSafetyMap. I have linked to the map and so can you.
I have then dropped into Pre-Notifications and Permissions (or the closest heading you have) and written:
“Flights within 1km of an HLS require the RP to raise a NOTAM via the CAAPortal. The radius of the NOTAM should be given as 1km.”
I chose 1km as the distance as this matches the smallest radius for which a NOTAM can be raised and therefore I am using this (in the absence of any figure from the CAA) as the definition of “in the vicinity”.
Be aware that I don’t know that this will be acceptable to the CAA, but I wanted to get something out there for anybody with a renewal coming up over the next few weeks. The CAA may start bouncing if something like this isn’t included in your manual.
There isn’t one!
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 firstname.lastname@example.org and let me know…I welcome constructive criticism.
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!