An update on Eyeup’s most popular blog of 2024
How to update your Operations Manual 2025!
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
An easier approach
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 £125.00 (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).
The CAA has now produced CAP 2606, their version of a PDRA01 compliant manual. However, on examination it will be found to be over-zealous in its approach. At over 120 pages it is both over-complex and designed merely around compliance, not ease of use or practicality. Operators are welcome to use the CAA template. But be warned that it contains a number of “gotchas” that may leave you liable if not followed to the letter. So make sure you understand what you are signing up to.
Eyeup PDRA01 Gateway
Application process changes
Since the last version of this “update” blog, the CAA has changed the way it approaches renewals. You no longer have to provide your Operations Manual, maintenance logs, flight logs etc. at the point of application. Instead, there is a “declarative system” for PDRA01 applications. This means you essentially tick the boxes to agreed that you will hold all the data and have an up to date manual and that you agree to being audited. You may, or may not be chosen for audit. It appears that around 20-30% of operators are chosen, though this is based on purely subjective data gathered from social media.
This declarative system is far faster in terms of processing, because there is no checking of documentation by the CAA at point of application. The CAA has stated an average of 23 minutes for processing, which is a vast improvement on the old “up to 28 working days”. The real time and effort is pushed “downstream” to the audit process, which can take some time to get through if you aren’t fully prepared. Don’t worry about this by the way. If you have a decent manual in place and follow it then you shouldn’t have a problem should you be contacted for audit.
I’m afraid that with the new system operators will no longer retain their existing UASXXXXX reference number if they renew. Apparently this was just too difficult as ask to build into the new digital processing system. Some operators have built this number into their websites and letterhead etc. so if this is you then you’ll need to check anywhere you may be using the number. I know some operators are justifiably proud of their low number references, gained back in the days of the original Permission for Aerial Work.
Cost structure changes
The cost of a PDRA01 Operational Authorisation sits at £234 at time of writing (December 2024). This is the same whether you are renewing or putting in a new application. The CAA originally wanted to change the fee to £314, but some strong pushback from Eyeup resulted in them backing down and dripping to the old renewal price plus inflation… hence the £234 price. An £80 reduction for every OA application (currently approx. 2900 for the year) comes to a total saving of £232,000 for the industry in the 12 months to April 2025… not to be sniffed at.
The silver lining
Okay, although you may lose your current authorisation reference number there is a potential small gain to be had from the changes outlined above. Lets look at the three main changes:
- Rapid application to authorisation issue time
- No retention of existing OA reference number
- Same cost for new application as renewal
Taken together there is no no longer an benefit in maintaining your OA up to date at all times unless you are making constant use of it. If you usually renew during a very quiet period of the year (my renewal is the beginning of January), then you can choose to wait a month or so until you pick up a job that requires the use of your operational authorisation. In my case (a real part-timer) I may not need the OA until the end of March. I can therefore wait until mid-March to raise a new application rather than a renewal. It’s only a one-off saving, but would essentially save my business the equivalent of 10 weeks, or a fifth of a year’s cost. That’s 20% or almost £50 left in my pocket rather than the CAA’s. I call that a small win.
This approach won’t suit every operator. If you use your authorisation constantly then it’s a no go. It also doesn’t help if you renew during a busy time of year for your flying.
Critical warning for April 2025
The above approach should also be avoided if you intend to delay your renewal beyond 1st April 2025. This is because at the time of writing the CAA is proposing a new OA fee of £500 (plus inflationary and system costs taking it up to £530). Now, this figure may not make it through the consultation process, but it is worth noting that if you are in a position to renew before April, then it is best to do so. The CAA has changed the rules on how early you can renew from a maximum of 90 days right down to 30 days. So you won’t be able to pop in a renewal request at the end of March to cover a natural renewal at the end of June I’m afraid.
Old News
This is the fifth 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 2024 version, 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 722H Compliance. What’s that then?
Version 3 of CAP 722H was released on 9th April 2024. Despite having had various errors pointed out twice, some of them still remain. You can find a review of the document, together with an Eyeup Oversight Report here.
Although not perfect, version 3 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 or 2024 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 you 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 2024 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:
CAP 722D V3 Search
The link you want may not be obvious. Looking for the caa.co.uk and CAA logo icon help identify the legitimate source. It should take you to a page like this where the latest version and date are given. Version 3 dated 16 April 2024 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. The CAA has started indicating these with red underlining, though who knows how consistent this approach will be or how long it will last. Changes to a document may directly impact your operations so try to understand them fully.
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.
CAP 722D V3
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 CAP 722H 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)
CAP 722 UAS Operations in UK Airspace – Guidance
CAP 722D UAS Operations in UK Airspace – Master Glossary and Abbreviations
CAP 722H Specific Category Operations: Pre-defined Risk Assessment Requirements, Guidance & Policy
CAP 1496 New Aviation Reporting Portal
(EU) No 376/2014. The UK mandatory Occurrence Reporting Regulation
(EU) No 2015.1018 The UK MOR Occurrences Regulation
You may have reference to CAP 382 Occurrence reporting Scheme. Feel free to leave this in. However, if you click through to CAP 1496 you will find in paragraph 2 a link to the CAA CAP 382 occurrence reporting page, so CAP 1496 covers all the bases and I tend to delete it. There has been no kickback from the CAA on this.
The last two on the list may be new to you. They have been added as a result of CAA feedback. It is odd that the CAA feels the need to include these, since they have gone to the trouble of distilling the UAS-related sections quite effectively within CAP 722. I’m afraid this provides further evidence of an overly complex regulatory regime.
Step 3 Compliance Statement
Your OM must contain a safety compliance statement. There are various versions of this, but they must reference the appropriate legislation correctly. Eyeup’s standard, which has passed many assessments and audits 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.”
I’m not sure if the CAA has spotted a potential conflict within this very statement, but it meets their requirements so we’ll let sleeping dogs lie.
Step 4 Qualifications
If you haven’t converted to a GVC by now, then YOU MUST DO SO. It has been a requirement since January 2024. DO NOT let remote pilots fly under your OM unless they hold a valid GVC.
Justin Glynn of Osprey Drone Training has been offering courses that have 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 CAP 722H) 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 CAP 722H 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 CAP 722H. 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 shows the mitigations in plain English rather than the CAA’s mitigation code and has had mitigations removed where these are automatically met by a professional operator. An example would be the use of GVC trained remote pilots, which is a given. But it does reflect the mitigations that will genuinely help to make operations safe and compliant.
Step 7 Optional but Recommended – Check your pre-notification section
From 25th January 2024, permission has been required to fly “close” to prisons and young offenders institutions. There is a list of those affected in the new law covering this change. Drone Assist and related drone apps have since been updated appropriately.
The zones extend out to 400m from the boundaries of the properties concerned, which could possibly have a large impact on operators in some urban areas.
An exemption is required to fly in these areas.
Such exemptions are issued by His Majesty’s Prison and Probation Service (HMPPS) and require the completion of an application via the Airspace Co-ordination and Obstacle Management system.
Flights above 400ft (close to tall structures) or flights involving multiple UAS, may trigger consideration of a NOTAM. There is a new ACOMS portal to enable this.
Step 8 Emergency Procedures
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 during audit that has never been caught during previous assessments. I’m afraid this is the result of the cut-price service we get from the CAA. They have never had a decent system in place to check manuals thoroughly, that’s just a sad fact.
The missing link
In many ways, this is the most important link. It will take you through to the Operational Authorisation application page. Good luck!
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 the operations manual is pulled up during audit due to an issue with the manual itself (i.e. not your application of it, for example failure to maintain records) 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
