An update on Eyeup’s most popular blog of 2023
How to update your Operations Manual 2024!
This blog takes time to write and time to keep updated. So here’s the deal. Use the blog to update your manual, remember the work I’ve put in and see your way to buying me a coffee
Edits
18/02/2024: Insertion of Emergency Procedure section from 2023 version at Step 9. Re-number previous step 8 and 9 to 9 and 10.
22/01/2024: Slight change to order of words in the “Safety Statement” based on a statement from the CAA to an operator. The operator hadn’t got it wrong in that they had taken the advice of a poorly informed or distracted CAA “adviser”. Evidence on file should the regulator wish to take me on about this one!
Making life easier
Eyeup has now created a fully CAP 722A and 722H compliant manual. If you want to have your complete manual refreshed to this document, then it’s easy to do.
Simply click here, complete the form and email your current manual to info@eyeup.camera. You will be invoiced £150.00 (Eyeup is not registered for VAT) and once paid, you will be sent an updated manual. It is important that you familiarise yourself fully with this new manual since it contains some differences to your current OM, driven by the recently released CAP 722H version 2 (as of 4th August 2023).
£150 sounds like a lot of money, especially when compared to other organisations charging around £125 or less. However, Eyeup is the company that has consistently held the CAA to account on the problems with CAP 722H. There can be few individuals with a better understanding of the PDRA01 guidance and the regulations behind them than Graham Degg.
Eyeup will continue to hold the CAA accountable until it produces documentation that is as correct as this manual template!
Eyeup PDRA01 Gateway
Or…the DIY option
If you are determined to update your manual yourself, then you have my full support. It’s something that Eyeup has done for years.
However, you need to be aware of the way the CAA’s shared services section seems to work. They have an inconsistent approach, meaning that somthing that didn’t get pulled up one year, may cause a hold the next year. Now, an application on hold isn’t the end of the world. All you need to do is interpret a cut and pasted response, which may be tricky in itself, then apply the required changes to your manual correctly, and then return it.
At this point, the CAA reserves the right to make a charge of £124 if you happen to have got something wrong in your update, or even slipped up on something silly such as a change to the date or amendment number.
If you are not confident in managing your manual, then you may wish to reconsider your method of update and give Eyeup’s system, detailed above, a try.
Old News
This is the fourth version of the “Update your Ops Manual” blog. There can be value in checking previous versions of the blog…if only to understand the type and scope of regulatory changes the industry experiences.
Previous versions can be found here for the 2023 version, here for 2022 version and here for the 2021 version
However, I would advise you NOT to go poking around these previous versions unless you are confident that you understand the regulatory structure and how it has changed as you may thoroughly confuse yourself!
I have a couple of other pages which may help you develop or improve your current processes. These can be used to tidy or improve your ops manual.
Drone Operations Manuals Tips and Tricks
Emergency Procedures
CAP 722A Compliance. What’s that then?
In December 2022 the CAA published version 2 of CAP 722A. This is the document which outlines the format and contents required for Operations Manuals. The document is aimed specifically at advanced operators who want to work beyond the conditions of a PDRA01 Operational Authorisation. However, the content of the “Volume 1” part of the template is what the CAA want to see in a PDRA01 manual (although in many cases to a lower level of detail).
Your manual will almost certainly work to an earlier version of the CAP 722A template, or possibly to a version from before the 722A document existed. There are many templated solutions around, many of which are based on outdated versions of the CAA’s “ideal”. This may not matter today. The CAA has historically accepted many variations on the theme. However, we know thet the regulator can be fickle, and they are within their rights to change their approach at any time and demand that operators follow the “correct” format in full. This is why Eyeup’s template was written from the ground up to match the new version of CAP 722A.
CAP 722H Compliance. What’s that then?
In December 2022, the CAA launched its CAP 722H document to loud fanfare. It’s true that the fanfare was played by the CAA Aviation Brass Band, but it was a fanfare nonetheless.
Unfortunately, the document was weak poor in many respects. You can read this blog and check out Eyeup’s Oversight Report if you want to dig into the weeds. After 8 months of review and delay, version 2 was launched to rather less fanfare. This document is still poor in many areas (again…there’s a blog about it and an amended Oversight Report).
Although far from perfect, version 2 if corrected in the right areas, is good enough to build a compliant operations manual around. It contains all the mitigations and links to record keeping etc. the regulator requires in order to accept a manual. The trick is to read through the document, then interpret the “risk assessment by numbers” table they provide. It intuitive or simple, and the risk assessment table does contain some errors that could lead to unsafe/illegal operations.
If you updated your manual using the 2023 version of this blog, then you should have caught most of the requirements in CAP 722H. This version of the update process can;t cover all of that again…it just covers the changes since the last blog was written. If you want to ensure yo are fully CAP 722H compliant, then you would need to assess you have 3 choices:
- Open CAP 722H, interpret the document and risk assessment, then amend your manual to take all the identified changes into account. Or…
- Assess your manual against the Update your Operations Manual 2023 blog. Or…
- The sensible approach. Get Eyeup Aerial Solutions to provide you with a fully compliant manual.
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.
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 alone.
Let’s enter Ops Manual Heaven!
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 and your accountable manager’s signature block. They just leave you with more places to update every time. The 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 your Document Reference Table
I won’t give the document dates and issue numbers here because they are subject to constant change. This is just the method to use to find the latest versions/dates to pop into your table against each document.
What you need to do here is input the current document name (e.g.CAP 722D) 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 are given. Version 2 dated 7 December 2022 in the example below.. The version and date are 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. Always link to the header page though, not the document itself as the header tends to remain stable across version changes.
Which documents should I reference?
Here are the documents I reference in my standard manual. I have also added what I understand the CAA to require as part of the CAP722H changes:
The Air Navigation Order, which can be found here: Air Navigation Order 2016 as amended by the Air Navigation (Amendment) Order 2022.
Until advised otherwise, I will be referring to it as the “Air Navigation Order 2016 as amended”.
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
CAP722D UAS Operations in UK Airspace – Master Glossary and Abbreviations
CAP722H Specific Category Operations: Pre-defined Risk Assessment Requirements, Guidance & Policy
CAP1496 New Aviation Reporting Portal
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 and I tend to delete it. No kickback yet.
Step 3 Compliance Statement
At the end of 2023, the CAA made another change to the preferred “compliance statement”. What is frustrating is that these changes are never published to the operators themselves. Instead, they are announced to the RAEs. Whether or not you get to hear of any changes will depend on how good your RAE is at communicating.
Anyway, the preferred wording at the time of writing this blog is
“All operations will be carried out in accordance with the issued Operational Authorisation PDRA-01 and abide by the requirements of Assimilated Regulation (EU) 2019/947 (the UAS Implementing Regulation), its AMC (Acceptable Means of Compliance) and ANO 2016/765 as amended.”
Mine has gone in as part of the statement by the Accountable Manager. Other manuals may vary.
Step 4 Qualifications
From 1st January 2024 any remote pilot flying against a PDRA01 OA must hold a valid GVC.
Although the CAA has extended the date by with a remote pilot can take a GVC “conversion course” (which can be shorter and cheaper than a full GVC), the need for a valid GVC at 1st January 2024 has not changed.
If you fly after this date without a VALID GVC and have an accident, you are likely to find that your insurance is invalid. The flight will then be deemed illegal and you could find that you have committed a long list of offences.
Justin Glynn of Osprey Drone Training has been offering a conversion course that has gained a lot of support within the community and is well worth approaching..
Step 5 UAS Technical Specifications
Although this is not a new requirement, I think it is worth mentioning here just to get the link in to the Dronedesk specification tool.
The CAA expects operators to have checked through the manufacturer’s specification for information. They accept that if certain parts of the specification are not made public by the manufacturer, then a “Not Advised” may be entered for this aspect.
You can still add UAS during the year without renewing your OM through the CAA. However, I would strongly advise that before flying a new drone under your manual, that you insert the appropriate technical specification sheet.
My advice is to gather together technical specification sheets (compliant with the format in CAP722H) and to insert them into a schedule or appendix at the end of your manual.
Further advice is not to agonise over producing these technical specification unless you are operating an unusual platform. That wonderful Dorian Ellis over at www.dronedesk.io may well have done the work for you. The man deserves a medal!
You can find his technical specification page here.
Step 6 Risk Assessment
Many manuals contains a standardised risk assessment that is suited to all flights. This is because there are certain hazards that exist every time we put a drone into the air. An example would be motor failure.
Unfortunately, the risk assessment provided in version 2 of CAP722H still contains some errors. The other issue with it is the layout. The RA uses a “mitigation by numbers” approach, which makes it difficult to interpret and use.
I would recommend that you read and understand the mitigation list at the end of CAP722H. At least check to see that the hazards in the CAA’s version match your own.
The Eyeup PDRA01 manual naturally contains a fully corrected and populated version of the CAA’s risk assessment. It has had mitigations removed where these are automatically met by a professional operator (e.g. the use of GVC trained remote pilots), but it does reflect the mitigations that will genuinely help to make operations safe and compliant.
Step 7 Optional but Recommended – Expand your pre-notification section
Be warned that during 2024, this section may need to be expanded at short notice.
For instance, from 25th January 2024, permission will be required to fly “close” to prisons and young offenders institutions. There is a list of those affected in the new law covering this change. However, I fully expect the NATS site, together with Drone Assist and related drone apps to be updated appropriately when the time comes.
The new zones will extend out to 400m from the boundaries of the properties concerned, which could possibly have a large impact on operators in some urban areas.
The current ability to overfly prisons at a height over 164ft will be removed. The height limit for each location is provided in the statutory instrument but this is given in feet above sea level. Looking at a prison I’m familiar with (it’s a long story), Gartree near Market Harborough, the statutory restriction zone will extend upwards to 800ft above sea level. Given the establishment’s location at around 390ft above sea level, it is clear that the regulations are designed to fit around the 120m statutory maximum for drones. I wonder how they would cope with Eyeup’s 1000ft ASL permission?
I’ve popped a 400m line from the prison boundary wo give an impression of the area that will be impacted by these changes. In this instance, the whole of the Gartree village will become a restricted zone for drones below 400ft.
Step 8 Emergency Procedures
People are still getting caught out on these.
You need emergency procedures to cover the following as a minimum. The one about abnormal environmental conditions may be missing from some manuals as it is being picked up the assessors: Think about what you’ll do if there is a rain shower, sudden wind gusts or increased wind speed or low temperatures (affecting battery and crew performance).
Fire
Flyaway
Pilot incapacitation
Abnormal Environmental Conditions and C2 Link Loss (see below)
Airspace Incursion
Loss of Separation Distances to uninvolved third parties (emergency landing procedures). This one appears to replace the concept of Accidental or Malicious Ground Incursion but I could be wrong. If I’m correct, a simple rename of your current EP will suffice.
Step 9 Manual Overview
I’ve kept this in from last year as it is still worth checking the following sections of your manual to ensure these details are covered. Read them carefully. Many don’t, which is why they have been surprised by the last one!
Roles and responsibilities:
The UAS Operator (the holder of the Operator ID) must comply with the responsibilities set out in UAS.SPEC.050 of Regulation EU 2019/947 which are:
- The UAS operator shall Designate a remote pilot for each operation
- Ensure that all operations effectively use and support the efficient use of radio spectrum in order to avoid harmful interference;
- Ensure that before conducting operations, remote pilots comply with all of the following conditions:
- Have the competency to perform their tasks
- Obtain updated information relevant to the intended operation about any flight restriction zones, restricted areas, danger areas or other legitimate UAS flight restrictions.;
- Ensure that personnel in charge of duties essential to the UAS operation, other than the remote pilot itself, comply with all of the following conditions:
- have completed the on-the-job-training developed by the operator;
- have been informed about the UAS operator’s operations manual
- have obtained updated information relevant to the intended operation about any flight restriction zones, restricted areas, danger areas or other legitimate UAS flight restrictions.
- carry out each operation within the limitations, conditions, and mitigation measures defined in the declaration or specified in the operational authorisation;
- keep a record of the information on UAS operations for the period indicated in the Operational Authorisation.
- maintain the UAS in a suitable condition for safe operation by:
- maintaining the UAS in accordance with the manufacturer’s recommendations
- Keep a record of all maintenance activity for a minimum period of 3 years and make such records available to the CAA on request.
Step 10 Double check!
Check everything. It is still possible that you may get pulled up on something that the assessor’s missed last year. I’m afraid this is the result of the cut-price service we get from the CAA. They do NOT check every aspect of every manual every year. That’s just a sad fact.
Guarantee
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!
On the other hand, if you sign up to the Eyeup PDRA01 gateway, then I will get your manual through. If it is put on hold for any reason relating to the Eyeup sections of the manual then those issues will be resolved.
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 info@eyeup.camera and let me know…I welcome constructive criticism, alerts of typos etc. I do guarantee that I respond more positively and faster than our dear regulator. But then Eyeup is just me and I have no legal department to answer to.
If you need some tricky work doing that an A2CofC or Operational Authorisation 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 full sized DJI drones in built up areas at very reduced clearances too.
Graham Degg
