Close to gaslighting – Part 1
The UK CAA, as a regulator has a clear position of power over the community it seeks to regulate. This power is probably strongest over the lower echelons of the unmanned aircraft sector, dominated by micro-companies.
Please note the title of this article. I’m not accusing the UK airspace regulator of being a deliberate gaslighter. However, I do question whether some of the behaviours exhibited recently by the CAA are common to those in a manipulative relationship.
Because the arguments concerned are quite detailed, and I care for the sanity of my readers, the article is split into three parts. Part 1 covers the way the regulator appears to use strange document control techniques to effectively discount feedback from the community. By doing so, they are essentially re-writing the history of their own documents.
Gaslighting often involves trying to convince the “victim” that history isn’t what they believe it to be. How would a regulator go about this?
One way is through the publication of documents. More specifically, ensuring that documents are controlled in such a way as to “revise” history.
What is unusual about the examples I’m about to give is that in both cases the trigger was for the review of a document appears to have been “community feedback”.
In the CAA’s “CAP” system, when a document is published it is dated and a version number attached. Here’s an example:
CAP 2356 was raised as an example during a discussion of UAS safety on the Geeksvana YouTube channel. A CAA representative introduced the document, the “CAA RPAS Safety Reporting Project” as a form of evidence to show how the CAA openly publishes evidence pertaining to the use of drones and whether or not they can be considered “safe”. The document was dated May 2022 (though it wasn’t first published as a CAP until 7th June ’22) .
Unfortunately, during the live review of the document, (at around 2:25:16 for those interested in watching via the link above), a photoshopped image was found of a large unmanned aircraft flying immediately outside the window of what appears to be a commercial passenger aircraft.
The presenter and other non-CAA contributors immediately called out the image (on page 24 of the document) as being not only a physical impossibility, but essentially a slur on the professional community because of the type of UA pictured.
A call was made for the image to be removed from the document, and indeed, shortly after, the image was indeed deleted by the CAA.
However, despite a change that was made in direct response to an outcry from the community, you would never know that this change had been made. There has been no attempt to show within the official record that the document has been updated.
At the date of writing this article (November 2023) the document is still marked as being published as a CAP on 7th June ’22.
Somehow, the concept of document management doesn’t apply in this case.
Any external organisation that may have downloaded the original document into its systems for review will still hold the first “version 1” version, containing the clearly biased image, rather than the version with the image deleted.
You can see how difficult it is to explain the situation when there are two “version 1” documents in circulation bearing the same date, as there is no way of distinguishing them without a complex explanation of the differences… this is why discipline in document control is so important.
A unique case?
But that’s just a one-off right? And it’s only a picture, not a meaningful piece of text. Surely a regulator will control document formally when wording has been changed, certainly for something beyond a typo?
It appears not.
Every year, the UK CAA releases a series of documents to inform the aviation community of its “Scheme of charges”. Essentially, these detail will it cost to apply for the various licences and permissions required to operate.
When the scheme of charges are released, a formal notice is issued via the CAA’s “SkyWise” system, making all those registered aware that the documents are available.
In the ever-changing world of drones, the scheme needed to reflect the introduction of authorisations based on the relatively new CAP 722H document. 722H had been released the previous December so it was important that operators were clear on the costs of obtaining or renewing their authorisations.
This year’s documents were released at version 1 dated 17 March 2023
Unfortunately, whoever drafted issue 1 of the General aviation scheme managed to slip up.
The wording in the section relevant to UAS operators reads:
“Specific category – Operational authorisation with pre-defined risk assessment (PDRA) (note 6): operations defined as PDRA within CAP722H
Case 1 Initial Charge: £2,029 Renewal: £580
Case 2 Initial Charge: £1,160 Renewal £580″
Sadly, the information is misleading. The charges shown actually relate to far more complex operational authorisations. The correct charges were detailed in the row below (£290 and £217 if you’re interested), but this was a clear error.
Mistakes happen. What is important is how an organisation responds when an error comes to light.
This one was spotted very quickly by Eyeup Aerial Solutions and reported to the CAA via a LinkedIn post on 17th March…the very day the scheme was published. I’m confident that the post was spotted, both because I have many followers within the regulator but also because the document was changed within a few days.
Then, on the 4th April I checked the document again. I was delighted to see that the appropriate change had been made (which can be seen in the image below. I wasn’t so pleased to note that the version number remained as “1” and the document was still dated 17th March, prompting a further LinkedIn post.
Oddly, over the short period of writing this blog, the header has now been updated to indicate release at version 2. The earliest this change from 1 to 2 could have been made was just after my LinkedIn blog of 4th April 2023, but the release date remains at 17th March 2023. I can be certain from my records that the change from version 1 to version 2 was not made on 17th March 2023.
Why does any of this matter?
Trust in these documents is absolutely critical for the industry. remote pilots operating in the specific category are overseen by the regulator, and compliance with their guidance is seen as a necessity in order to retain that authorisation. The CAA maintains the power to revoke an authorisation and possibly destroy a business at any point. It is therefore critical that operational manuals are based on a known datum. That datum is usually specified in the manual in a reference table where the guidance document’s name, version and issue date is specified. Woe betide an operator that chooses to reference a document but gets one of the key details wrong.
Yet we have proven that the foundation of these documents may be built on shifting sands. Changes can and are made to documents without the version number and/or the document date being amended.
For as long as the CAA continues to demonstrate its inability to control documents effectively, I would warn all specific category operators to hold their own copy of any guidance documents they reference in their operations manuals. Consider it a cheap form of insurance.