45% Price Hike for Operational Authorisation Renewals!
Unlike some regulators, when changes are made, Eyeup like to keep you informed. There is an urgent update to this blog which can be found at The Listening Regulator – The CAA reverses its proposed 45% price hike!
For those readers who follow Eyeup on LinkedIn, you may recall a recent post. Looking back on it now, it seems naïve to think that the situation would be as simple as I had described it. That post can be found here. But to save you clicking through it can be summarised thus:
The CAA proposed in its annual Scheme of Charges consultation that the costs associated with general Aviation (which includes drones), will rise by 8.3% for 2024/25. Further more, it was stated that “There are no proposed structural changes to this Scheme.”
Because we love evidence here I have included the section from page 20 from the CAP 2596 consultation document:
How are the UAS charges structured at present?
They can be found in the CA document ORS5 No. 404 “CAA Scheme of Charges : General Aviation. Note: that after the 1st April 2024, this link may take you to the new charges, so I have reproduced the appropriate section of the current (at time of writing) 2023-24 version below.
The structure of the charges is very simple. There is a charge for new applications. An operator gains the appropriate qualification (usually the GVC), completes an operations manual and applies via the CAA’s online form for an Operational Authorisation. More complex operations can be permitted by completing an Operating Safety Case. A fee is paid and the appropriate OA is issued.
The other part of the structure covers renewals. The OA is renewable each year. Of course, during a renewal, the CAA already holds a lot of information about you as an operator. You do have to send a couple of logs as evidence of compliance, and the CAA claims to check your manual. But this has always largely been a “box-ticking” exercise. I’d love the CAA to question this last statement as the evidence is undeniable that manuals are not checked properly and many renewal applications are placed on hold for spurious reasons.
Let’s take a look at this relatively simple structure:
The CAA has stated that it wishes to make this process more reliable and efficient. Hats off to them for that. But have they done so?
Increased efficiency should lead to lower costs. I can understand that the step to efficiency may require investment and presumably that’s what part of the 2024/25 3% Future Flight surcharge is all about. But it is becoming clear that the proposals in the consultation may be subjected to a bit of late back-pedalling.
Following the LinkedIn post detailed above post It was brought to my attention that the CAA has an entirely different definition of “structure” to the industry (and probably the rest of the world). This must be the case, because their plan for 2024-25 looks very different.
Let’s recap briefly.
The CAA has stated clearly that the General Aviation scheme will not be subject to any change in structure.
The UAS section of the GA scheme has a structure comprising a charge level for an Initial application and a reduced charge for a Renewal application. It has always been thus.
Imagine my surprise when I was made aware of the following in an email sent to the RAE community. Note that again. This message has been sent to the training organisations…but not to the operators who will be responsible for paying the additional charges. Anyway, to the statement:
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 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 be one fee for both initial and renewal applications.”
Read the last sentence again: “There will be one fee for both initial and renewal applications.”
What this means in reality is that the CAA charge for a renewal will rise from the current 23/24 fee of £217 to the new “fixed” fee of £314 from 1st April 2024. That’s a massive 45% pike hike!
At the time of writing, the regulator hasn’t published its 2024-25 Scheme of Charges. When it does, for PDRA01 applications, based on the email above, from a reputable source, I assume it will look something like this:
Now, that looks a lot like a change or structure to me. It certainly doesn’t represent the 8.3% increase for renewals as clearly stated in the consultation document.
By the way, the regulator has a history of getting the Scheme of Charges wrong, though they never admit to it even in their document control. Fortunately, some of us are on the ball and help them out when they drop the ball. See Eyeup’s blog which includes details of their error (and subsequent cover-up) in the 2023-34 Scheme. For this reason, I have maintained copies of all of the CAA produced documentation used in this blog.
Can we affect this?
To be honest, I simply don’t know.
However, I would recommend two courses of action.
The first is to email enquiries@caa.co.uk and express your concern as a PDRA01 OA holder that the CAA is breaking the terms of its own proposal on charges.
The second is to consider getting a renewal in as quickly as possible. If you are going to have to pay almost £100 more from the 1st April, then renewing, even before the 90-day window, may be worthwhile. There is a risk that the regulator will change its mind and we will fall back to an 8.3% increase on the renewal fee, bringing it back from £314 to a more reasonable £235.
Naturally, Eyeup is ready to help with operations manuals updates. To that extent, if you choose to use my services for your operations manual update before the 1st of April 2024, and mention this blog in your email, I will reduce the price from £150 to £125.
The link to access Eyeup’s update service is here: Welcome to The Eyeup Operations Manual solution – Eyeup Aerial Solutions
To be honest, I would rather get zero business and force the CAA to meets its obligations under the consultation!
