I wish to make it clear that I am 100% behind competent and proportionate regulation of UAS in the UK.
We need to keep people safe and regulation should allow this.
However, any regulated community must feel they are being dealt with in good faith.
You can also find a video discussion of the issues covered in this blog here.
Let us begin.
The CAA has recently completed its annual Scheme of Charges” consultation. The RPAS section has caused some controversy as prices are rising in some cases by several hundred percent.
Much of the cost increase is “justified” by the introduction of SORA and DiSCO systems. You can read more about this in the blog “CAA 2025/26 Scheming of Charges“.
Such increases don’t go unremarked by the industry and several organisations and individuals were sufficiently concerned to start asking questions of the CAA through the Freedom of Information Act FOIA) process. Their aim was to find out more about the consultation work the CAA had carried out that made them confident in the industry’s desire to implement the SORA and DiSCO systems.
This blog seeks to expose potential issues around those consultations.
What prompted my concern?
A contact was good enough to send me the results of a FOIA request which you will find below:

Original FOIA Response – OA holders industry group
Who is the OA holders industry group?
This was a puzzle. When the CAA consults with ARPAS, they will generally name the organisation. But ARPAS wasn’t named here, just an anonymous-sounding “industry group”. Consider my interest well and truly piqued.
When in doubt, it’s always good to ask, so I thought I’d go straight to the well established Commercial Drone Pilots (UK) Facebook group to see if anybody knew, or were involved in the mystery group. If you are a member, my original post can be found here.
There were several interesting responses:
- It became clear that senior members of ARPAS had no clue what the CAA were referring to
- Many operators were keen to identify the group… and understand how to join it so they could add their opinions
- There was a fascinating response from Angus Benson-Blair almost denying that it had anything to do with him!
The first two responses are perhaps obvious. ARPAS weren’t named and many operators wanted to join any group that they perceived had some sort of influence with the regulator. I’m going to jump straight to point 3. Here is the short discussion between Angus and myself that continued offline.
As you will see, my initial response was to discount the OA holder industry group as having anything to do with a group I had some involvement with… a little gang referred to in my response to Angus and known as the “UK CAA OSC Exemption Holders” Facebook group.
Time for a sidebar
What is this UK CAA OSC Exemption Holders group all about then?
Well, back in November 2021, I set up a Facebook group to bring together members of the community that hold OSC-based Operational Authorisations.
Here’s an early post, which turned out to be a trifle naïve.
“If we can get a good sized group together (and there’s no reason to believe we can’t), then I hope we can get a seat at the table with the CAA to represent the specific needs of the OSC community”.
Well, we did get a decent-sized group together. Currently we have a membership that represents close to half the UK OSC-OA holders. You’d have thought that this would be more than enough to gain “key stakeholder” status. But the CAA keeps its doors pretty firmly barred…except, back in Q3 of 2023, driven by the indefatigable Angus, we manged to gain an audience in-person on the premises of the CAA at Aviation House, close to Gatwick Airport. This is the meeting referred to in the Facebook post above and which we promptly discounted. Why? Because “our” meeting was to cover a bunch of issues to do with processing of OSC applications, including staff competence
The areas covered were:
- CAA not applying a risk proportionate approach to OSC
- No service level agreement
- CAA demand a blank cheque
- Lack of Consistency
- Communications, department fails to communicate at all. ‘Sudden insistence of horizontal distances without warning’
- Timescales – process takes too long
- Approach of staff, staff do not present themselves as wanting to work with you to get to the end of the process
- Competence of Staff
Remember these subjects…
Back to the FOIAs
In the new year I returned to the puzzle. If it isn’t ARPAS and it isn’t the group I was involved with, what was the mystery OA holders industry group?
So I went back with a slew of detailed questions. These can be found here, together with the CAA’s response. Thanks whatdotheyknow.com!
The questions I asked were:
- What is the “OA holders industry group”?
- Do the members of “the OA holders industry group” hold PDRA01 OAs, or ORA-based OAs or a mixture of both?
- Is the “OA holders industry group” ARPAS Ltd?
- Is the “OA holders industry group” a group composed of ORA-based OA holders who met with the CAA in H2 2023?
- Please provide the dates of the several meetings held with the “OA holders” industry group”.
- Please provide notes of the several meetings held with the “OA holders industry group” relating to the “questions from industry on challenges with the current operational authorisation process that the implementation of SORA and DSCO will resolve”.
Some surprising answers
Anybody can go to whatdotheyknow using the above link. The CAA’s response is numbered F0007162. There you will be able to read the reply in detail and ensure I am being totally honest. But for ease, here is the reply in full.
- The ‘OA Holders group’ was made up of approximately 15 OA holders that collectively approached the RPAS Sector Team on their own initiative to help address a collective concern aimed at reducing the average time it takes for a successful application to be made and an Operational Authorisation issued.
- At the time of the last meeting, it was a mixture of both.
- No.
- Yes.
- There were a number of interactions including an in-person meeting at Aviation House on 29 September 2023.
- Notes from the meetings were not kept, however, for the purposes of transparency the CAA Response following the 29 September 2023 meeting are attached.
It was the response to the final question that confirmed the identity of the group. Against our own expectations, it turns out that the group was indeed the UK CAA OSC Exemption Holders group. This was confirmed not only by the date of the meeting (29th September 2023), but by the attached notes. These are identical to those sent to Angus after the meeting and can be found here in the FOIA response.
The CAA – not good with numbers… or notes for that matter.
Let’s review the responses:
- The meeting involved 18 OA holders, not 15. This perhaps reflects the CAA’s interest in the meeting? The reason for the meeting given is a little disingenuous. You have seen the agenda, and it covers a far wider range of problems. Perhaps the regulator is embarrassed about some of these?
- Yes, some of the meeting members will have held both a PDRA OA and an OSC OA. But the meeting was 100% about OSC applications. We’ll let this one go on a technicality. It’s worth picking up on the word “last” here. This continues to imply more than one meeting. However, my contention is that only one meeting took place. The fact that the CAA is unable to provide notes from more than one meeting if pretty convincing evidence for this.
- It wasn’t ARPAS. Fair enough. Though if I were an ARPAS member, I’d be asking why the trade association wasn’t involved.
- This answer begins to confirm that the group may be the OSC holders Facebook group.
- This is interesting, the regulator has shifted its position from “several” meetings were held, to “a number of interactions including an in-person meeting”. It is clear that there was only one meeting. Other interactions were those involved in setting up the meeting and then a number required to chase up the CAA response, a process that took until the 8th November.
- “Notes from the meetings were not kept.” How can a regulator include within a consultation the results of meetings which they have absolutely no record of? Of course, there is a more fundamental question. How can a regulator claim that entirely fictional meetings have taken place? The industry could just as well claim that they attended 300 meetings during which there was zero support for DiSCO or SORA. Fictional meetings don’t matter. The notes that were produced, took over 5 weeks and the group has seen zero improvement in the processes concerned. Some would say it has worsened.
Systemic issues
When the CAA has been questioned in good faith, has it decided not to be truthful in its responses, or is a lack of competence in record-keeping leading to confusion? Neither would be a great look.
Can the CAA count? 15 people and 18 people are different numbers. There is a lack of respect shown here. Which 3 of the 18 attendees were essentially ignored?
Why does the CAA use the word “several”? Does it not understand that the word means “a minimum of more than two”? Only one meeting took place, not two, not three or more. Is it deliberately “boosting the figures” in an attempt to convince stakeholders that there is more support for its systems than actually exists?
If we look at some of the other claims about the consultation we will find claims such as:
“we have spoken with 43 different users between November 2022 and November 2024.”
In CAA-speak, which we are beginning to understand, what does that mean? Have members of the team spoken with industry operators about a disco they attended? If the operator agreed that they love a good bop, would that be noted as a firm affirmation of the introduction of the DiSCO system?
If the regulator thinks it is acceptable to avoid taking minutes of meetings, how can they possibly evidence the support they claim? What happened to evidence?
Has there been a consultation where operators were told that their costs would be increased several fold in a single year because of the implementation of these systems? That is the fair way to approach these changes.
But I’ll leave you to decide, dear reader, if you believe the industry is being treated fairly.