• This SAFER webpage is where the progress on Safety Recommendations (SRs) assigned to the CAA by the Air Accidents Investigation Branch (AAIB), the UK Airprox Board (UKAB) and other State Accident Investigation Authorities can be found.  

    To continuously learn and improve, we have reviewed how we deal with all aspects of our Safety Recommendation Management. As well as responding to SRs and acting where appropriate, our responses are independently evaluated and the through life management of the activity is now recorded and reported on centrally, providing assurance that we deliver on our commitments. Taking this one step further, we will analyse our responses and actions using bowtie methodology, ensuring that safety interventions are reflected in the bowtie Controls and that the bowties remain current. 

  • Accident DJI Phanton 4 RTK

    RPAS - No Registration (Newtongrange, Midlothian)

    AAIB Bulletin: 6/2021 DJI Phantom 4 RTK AAIB-27058

  • Recommendation text

    It is recommended that the Civil Aviation Authority collate up to date information regarding the failure rates per flying hour for unmanned aircraft systems operating in the Recommendation text
    Specific category, or previously under a CAA Permission for Commercial Operations, to facilitate effective risk assessments.

    Recommendation Response

    The CAA partially accepts this recommendation.  Most flying hours accumulated by smaller commercial off-the-shelf UAS in the UK are carried out in the Open Category, which the CAA does not have visibility of.  The CAA accepts that Open Category products like this will be used under an Operational Authorisation (OA) in the Specific Category.  Regulation (EU) No. 2019/945 as retained (and amended in UK domestic law) under the European Union (Withdrawal) Act 2018 requires that the Secretary of State nominate a Market Surveillance Authority (MSA) that will have responsibility for ensuring that manufacturers adhere to appropriate standards.

    Part of the remit under UK Reg (EU) 2019/945 is that the MSA will engage with the CAA on safety matters and help ensure that products are suitably safe for market and use in the UK.  This coupled with the C-marking standards defined in the regulation will assist in ensuring that equipment used in the UK is of high quality, and the MSA will assist in ensuring that manufacturers continually improve their products.The collation of all flying hours across multiple product lines and manufacturers will not be feasible.

    The collection of hours flown by type in the Specific Category is difficult due to the temporary nature of many applications.  An Operational Authorisation is typically valid for a year, and there is no compulsion on the applicant to renew.  This means that following the issue of the OA, unless Performance Based Oversight (PBO) principles means there is a requirement identified to audit or examine the applicant, the CAA may have no further contact with them.  The provision of full logs is not currently a requirement under any existing legislation; only a confirmation of currency within the 3 months preceding the application or renewal.

    Under UK Reg (EU) 2019/947, point UAS.SPEC.090, any holder of an Operational Authorisation must make any records available to the CAA on request.  The CAA will examine whether the application and audit processes could be expanded to use this privilege to retain logs by aircraft type at the point of renewal or expiry of a Specific Cat OA.

    Update Due

    01/04/2022

    CAA Status

    Open - Tracked Actions

    Recommendation text

    It is recommended that, until an analysis of failure rates per flying hour has demonstrated an acceptable level of safety, the Civil Aviation Authority should consider prohibiting the overflight of uninvolved persons for those unmanned aircraft operating in the Specific category which rely solely upon their propulsion system for lift that would, following a failure of the propulsion system, impact the ground with a kinetic energy exceeding 80 Joules.

    Recommendation Response

    The ability to conduct a root cause analysis of the accident was frustrated by the rapid dispatch of the aircraft to the manufacturer for repair; important safety conclusions may have been missed.  Neither Regulation (EU) No 376/2014 as retained (and amended in UK domestic law) under the European Union (Withdrawal) Act 2018, nor CAP722 specifically inform reporters that they should retain any material from the accident for potential investigations.  The CAA will consider what advice should be added to a future draft of CAP722 regarding the preservation of evidence once suitable lines to take have been agreed with AAIB.

    Overflight of people is permitted by regulation under UK Reg (EU) 2019/947. The CAA has not seen enough evidence that indicates that the prohibition of   overflight of uninvolved people is a proportionate response to this accident. Authorisations to fly in congested areashave operating conditions and require a higher level of remote pilot competence to mitigate the safety risk it  presents.

    The CAA will conduct trend analysis of occurrence reporting and will release an appropriate message to the regulated community to reinforce good practice on how to reattach propellers and remind operators to conduct root cause analysis to close MORs.

    Update Due

    None

    CAA Status

    Closed


  • Serious Incident G-LAWX

    G-LAWX - Sikorsky S-92A (nr Shipston-on-Stour, Warwickshire)

    AAIB Bulletin: 8/2021 G-LAWX AAIB-26196

  • Recommendation text

    It is recommended that the Civil Aviation Authority publish guidance on the meaning and intention of the phase of flight alleviations in UK SERA where detailed as “except for take-off and landing” to better enable pilots to plan and act on minimum height requirements for safe operations.

    Recommendation Response

    The CAA accepts this recommendation. A review of available guidance for the meaning and intention of the phase of flight alleviations in UK SERA (where detailed as “except for take-off and landing”) will be undertaken and if appropriate suitable guidance will be issued.

    Update Due

    TBC

    CAA Status

    Open - Awaiting response

    Recommendation text

    It is recommended that the Civil Aviation Authority encourage the development and deployment of Point-in-Space operations at landing sites.

    Recommendation Response

    The CAA accepts this recommendation. The CAA recognises safety and operational advantages are possible by developing Point-in-Space operations and will work with industry to encourage deployment through the Onshore Safety Leadership Group.  However, the CAA is also cognisant that it is up to industry (operators and landing site owners) to identify most appropriate PINS applications, and that there is currently an industry cost burden in the development of such procedures which is an impediment to wider availability.

    Update Due

    TBC

    CAA Status

    Open - Awaiting response

    Recommendation text

    It is recommended that the Civil Aviation Authority revise its guidance on helicopter flight in degraded visual conditions to include further information on managing the associated risks.

    Recommendation Response

    The CAA accepts this recommendation and will conduct a review of its current guidance on helicopter flight in degraded visual conditions with a view to providing enhanced information on the importance of the management of associated risks as exemplified through elements of this serious incident.

    Update Due

    TBC

    CAA Status

    Open - Awaiting response

    Recommendation text

    It is recommended that the Civil Aviation Authority ensure that operators show clear evidence within their system for operational control as required by UK ORO.GEN.110 (c), of how the tasking process separates the customer from the flight crew.

    Recommendation Response

    The CAA accepts this recommendation. The CAA has conducted a Specific Objectives Check (SOC) relating to operational control as required by UK ORO.GEN.110 (c) and other associated AMC and GM materials, a number of observations have been raised with operators to address any shortcomings in their systems. As a result of this recommendation and the observations raised, the CAA is reviewing their guidance to operators. The CAA will also engage with relevant industry groups to promote awareness of, and compliance with, the relevant requirements.

    Update Due

    TBC

    CAA Status

    Open - Awaiting response

    Recommendation text

    It is recommended that the Civil Aviation Authority assess the safety benefits and feasibility of Helicopter Flight Data Monitoring programmes for onshore helicopter operators conducting commercial operations or non-commercial complex operations and publish its findings.

    Recommendation Response

    The CAA partially accepts this recommendation. The CAA recognises the benefits of the principle of Flight Data Monitoring (FDM) and would encourage Onshore Operators to establish an appropriate programme as part of their Management System. However, the CAA is also conscious of the constraints and limitations placed upon small operators and the challenges they face but will work in close collaboration with the Onshore Leadership Group to progress the safety priorities published in CAP1864 (Onshore Helicopter Review Report) in Nov 2019 including the consideration for FDM for all commercial operations and non-commercial complex helicopter operations.  If it was so determined that FDM should be mandated for this sector then this would involve the development of a new Rule Making task which would include a full safety and cost benefit analysis that would necessarily involve public consultation and justification.

    Update Due

    TBC

    CAA Status

    Open - Awaiting response


  • Serious Incident G-POWN

    G-POWN - Airbus A321-211 (Gatwick Airport)

    Aircraft Accident Report: 1/2021 G-POWN AAIB-26436

  • Recommendation text

    It is recommended that the Civil Aviation Authority (CAA), during future audits of CAA-approved Continued Airworthiness Management Organisations and Approved Maintenance Organisations, include a check that consideration has been given to the classification of biocide treatment of aircraft fuel systems as a critical maintenance task.

    Recommendation Response

    The Civil Aviation Authority (CAA), as part of its future audit oversight programme for Continued Airworthiness Management Organisations and Approved Maintenance Organisations, will review the use of critical maintenance task methods and procedures highlighting to organisations, including the classification of biocide treatment of aircraft as indicated within the AAIB Report. This will include the need to follow the guidance material as set out in GM M.A.402(h) or AMC2 145.A.48(b) for data sources used for the identification of critical maintenance tasks which includes accident reports.

    As an additional mitigation the CAA will amend its guidance material on the creation and amendment of Aircraft Maintenance Programmes to include additional guidance on identification of critical maintenance tasks highlighting the above mentioned regulatory references and the need to place additional focus on Biocide treatment of aircraft.

    As the regulatory framework within the UK is now separated from that of the EU, the CAA will also instigate a rulemaking task to amend the AMC as indicated in safety recommendation 2020-018 and 2020-019 for the UK legislation.

    Update Due

    April 2022

    CAA Status

    Open - Awaiting response


  • Serious Incident G-ZBKF

    G-ZBKF

    AAIB Bulletin: 5/2021 G-ZBKF AAIB-26975

  • Recommendation text

    It is recommended that the Civil Aviation Authority require that passenger seats in commercial air transport aircraft are designed to minimise the chance of portable electronic devices becoming crushed in mechanisms.

    Recommendation Response

    The Civil Aviation Authority (CAA), as part of its future audit oversight programme for Continued Airworthiness Management Organisations and Approved Maintenance Organisations, will review the use of critical maintenance task methods and procedures highlighting to organisations, including the classification of biocide treatment of aircraft as indicated within the AAIB Report. This will include the need to follow the guidance material as set out in GM M.A.402(h) or AMC2 145.A.48(b) for data sources used for the identification of critical maintenance tasks which includes accident reports.

    The CAA partially accepts this recommendation and supports the Safety Action taken by EASA in regard to requesting the SAE International Seat Committee develop design standards and/or recommended practices in relation to the design of seats for commercial air transport aircraft to minimise the chance of portable electronic devices becoming crushed in mechanisms.

    Evolution of  seat design standards will benefit from a global position and the CAA will work with the international regulatory community to review supporting evidence and global data that may support future amendments to global and UK Certification Specification and/or recommended practices.

    Update Due

    March 2022

    CAA Status

    Open - Awaiting response


  • Airprox RV9/Phenom

    Vans RV9 & Embraer Phenom 100 (Turweston)

    AIRPROX REPORT No 2020167

  • Recommendation text

    The CAA conducts a review to establish the reasons behind why many training airfields chose not to maintain their ATZ when the requirement to hold an aerodrome licence to conduct training activity was removed. Where whose reasons fall within the competency of the CAA - take appropriate action to mitigate against any increase in risk associated with the removal of the protection previously afforded to them (by an ATZ).

    Recommendation Response

    In responding to the recommendation, it is worth reviewing the background.

    In April 2010, the Air Navigation Order (ANO) was amended to allow some forms of flying training activity to be undertaken at unlicensed aerodromes.  This followed recommendations from the CAA's Light Aviation Airports Study Group (LAASG) - that was formed jointly with industry in 2005 - to consider changes to regulation specific to light aviation.  Research conducted by the LAASG indicated that neither ICAO nor the then extant Joint Aviation Authority (JAA) requirements required flight training or testing for a licence, rating or certificate to be conducted from a certificated or licensed aerodrome.  After analysing the available safety data, the LAASG concluded that there was no justifiable safety case to require flight training in light aeroplanes and light helicopters to be undertaken at a licensed aerodrome.  Industry members of the LAASG cited the cost of maintaining an aerodrome licence as a disincentive to the flying training sector.

    As a consequence of the LAASG's work, detailed proposals were developed by the Flying Training Sub-Group (FTSG) (comprising members of the CAA and industry representatives from the LAASG) to remove the requirement for flying training to be conducted at licensed aerodromes.  These proposals were consulted upon and subsequently enacted through amendments to the ANO.  This change prompted a number of aerodrome operators to opt to surrender their aerodrome licence, with evidence indicating that this was done in order to reduce costs.

    To the first element of the UKAB's recommendation regarding the aerodrome traffic zone (ATZ), the 'Letter of Intent' to amend the ANO was published in February 2010.  It specifically described the implications for an ATZ should an aerodrome choose to surrender their aerodrome licence, stating:

    “Whilst there is an indirect link between a[n aerodrome] licence and the establishment or maintenance of an ATZ the primary driver is the level of air traffic service - air traffic control (ATC), aerodrome flight information service (AFIS) - or air/ground support established at an aerodrome. Unless supported by ATC or AFIS, an ATZ will be withdrawn on revocation of the aerodrome licence. Whereas a licensed aerodrome - with an associated ATZ - need only be served by a “means of two-way radio communication” (air/ground), an unlicensed aerodrome requires the support of an ATC or AFIS unit. The difference is associated with regulatory oversight. An unlicensed aerodrome and an unregulated  'service' (air/ground) would give the CAA no process to ensure that the airspace was being appropriately managed. In order to prevent such a situation an unlicensed aerodrome will need a minimum of AFIS for the establishment or maintenance of an ATZ to be considered. Promulgation of ATZs at aerodromes that are not licensed is not an issue. Such ATZs already exist (mainly in association with Government aerodromes) and are promulgated in the AIP at ENR 2.2.”

    This text refers to long-standing CAA policy that the combination of “an unlicensed aerodrome and an unregulated aeronautical radio station” (i.e. providing an air/ground communications service (AGCS)) would result in an unacceptable lack of regulatory oversight aimed at ensuring that the airspace was being appropriately managed.

    It is important to thus highlight that individual aerodrome operators chose whether to surrender their aerodrome licence, with many choosing to retain their licence.  In those cases where aerodromes chose to surrender their licence, based on the evidence available, it appears that the decision was based, primarily, on the grounds of cost, and was made fully cognisant that a consequence of that decision would be the loss of the ATZ (where an air traffic service was not provided).

    In terms of safety risk(s), one critical aspect of the changes to the ANO was the requirement  for the commanders of aircraft, and the operators of aerodromes, being used for flying training to satisfy themselves that the aerodrome is safe for that purpose.  In order to assist aircraft commanders and aerodrome operators in fulfilling this requirement, the CAA published CAP 793 'Safe Operating Practices at Unlicensed Aerodromes'.

    CAP 793 states that “where flying training is taking place, additional safety margins should be considered”, emphasising the ANO Article 209 requirement.  CAP 793 goes further, recommending that “adequate risk assessments are made and documented before flying training takes place”, and highlighting that “such documented risk assessments may be necessary to prove to the CAA and other authorities in the event of an accident or incident that an aircraft commander or aerodrome operator has had sufficient grounds to be satisfied that the aerodrome is safe for flying training”.

    The CAA expects that such risk assessments would consider issues such as the nature of the flying operations at the aerodrome, the local airspace and its complexity and the need for the protection afforded by an ATZ in determining that the aerodrome is a safe environment for the conduct of flying training.  We would also anticipate that those risk assessments are subject to ongoing review, in accordance with the aerodrome or aircraft operator's safety management systems, to ensure that the risks continue to be tolerable and mitigated to a level that is as low as reasonably practicable.

    Whilst the CAA seeks to influence beyond our established Regulatory authority, for the purpose of this response, it is perhaps useful to describe the extent of that authority vis-a-vis aviation activities at unlicensed aerodromes.  Our oversight teams have no regulatory remit for aerodrome oversight (with the exception of the storage and dispensing of fuel), nor are they resourced for routine oversight of the provision of AGCS.  The General Aviation Unit (GAU) does undertake oversight of approved and declared training organisations (ATO and DTO respectively) at unlicensed aerodromes but their remit is limited.

    ATOs are required  to establish, implement and maintain a management system that includes the identification of aviation safety hazards entailed by the activities of the organisation, their evaluation and the management of associated risks, including taking actions to mitigate the risk and verify their effectiveness.  Where the ATO operates from an unlicensed aerodrome, the GAU reminds them of their responsibilities under Article 209, which includes a specific assessment of the risk to circuit traffic in the absence of an ATZ.

    Whilst the GAU reminds DTOs of their responsibilities under Article 209, there is no explicit requirement placed upon them to consider aviation safety hazards in the same way as for ATOs.  A DTO is required  to develop and establish a safety policy which ensures that the DTO's activities are carried out safely, and thus consider the hazards to their operations.

    A review of our oversight intelligence indicates that:

    • whilst ATOs that operate from unlicensed aerodromes have identified airborne conflict in the aerodrome traffic circuit as a risk, those ATOs consider the risk to be tolerable.  In some cases, the stated mitigation is that the aerodrome is depicted as a training aerodrome on the aeronautical chart(s);
    • where we have undertaken audits of DTOs at unlicensed aerodromes , some of those organisations had not considered the risk of airborne conflict in the aerodrome traffic circuit.  They have been asked to consider this in discharging their responsibilities under Article 209 and Part-DTO.  That said, we are aware that, following airprox 2018319, Hull Aero Club at Beverley contacted local military airfields to raise awareness of their location.

    It is important to note that, where the operator of an unlicensed aerodrome believes that an ATZ may be a viable mitigation to perceived safety risk(s), the option to establish an ATZ remains open.  Subject to the provision of an air traffic service (either ATC service or AFIS), unlicensed aerodromes may seek to establish a ATZ in accordance with CAA Policy on Aerodrome Traffic Zones (ATZ).  This states that the establishment of an ATZ will be progressed as a Level 2C airspace change in accordance with CAP 1616.

    On 23 October 2020, CAP 1886 “UK Approach to Recreational General Aviation Safety: An Independent Review” was published.  This work, commissioned and funded by the Department for Transport, concluded that “the current safety level of recreational General Aviation in the UK is acceptable viewed in terms of its unavoidably greater risk than commercial aviation, the much higher risk acceptability of voluntary activities and in comparison, with other high-risk activities”.  It went on to say that “Additional regulation is not justified and is unlikely to significantly improve safety”.

    Given the limited oversight levers and the restricted latitude offered the CAA by the conclusion drawn in CAP 1886, the remaining course of action open to the CAA would be to review CAA policy vis-a-vis the notification of an ATZ at an unlicensed aerodrome where an air traffic service is not provided.  As previously stated, the CAA's established position is that such an arrangement would not currently receive an acceptable level of regulatory oversight to ensure that the ATZ was being appropriately managed.  Moreover, it is worth highlighting that a very course analysis of incident data, including the UKAB's own data, indicates that there may be underlying issues at such unlicensed sites that our current level of regulatory oversight is both unable to investigate and address.  It should also be noted that the granting of an ATZ other than at a licensed (or certificated) aerodrome would (as a solution) generate multiple 'knock on' impacts.

    Nevertheless, the CAA undertakes to review its position regarding what we would consider to be an acceptable level of regulatory oversight for the purposes of airspace management, and we will report back to the UKAB once that work is completed.  Please accept this as our initial response to your recommendation.

    Update Due

    TBC

    CAA Status

    Open - Tracked Action


  • Accident Alauda AS MkII

    RPAS - No Registration (Goodwood Aerodrome)

    AAIB Bulletin: 3/2021 Alauda Airspeeder Mk II AAIB-25876

  • Recommendation text

    It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722; Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy, to require detailed evaluation of any Unmanned Aircraft Systems that use onboard systems to mitigate risks with a Risk Severity Classifications of 'Major', 'Hazardous' or 'Catastrophic'.

    Recommendation response

    The CAA accepts this recommendation:
    The RPASU has recruited an RPAS Technical Inspector with a specific background in airworthiness and avionics engineering, who has spent recent years working as an SMS and safety specialist for complex RPAS operations.  This allows the RPAS Sector Team (RPASST), who have responsibility for the assessment of Operating Safety Cases (OSCs), to deploy in-house airworthiness experience for the analysis of specific aircraft or systems.

    A policy has been built and will be approved in the near future to trigger the involvement of other capability areas when in-house expertise is insufficient, calling on resources from the CAA's Cyber and Airworthiness capability teams.  The other capability teams will be consulted on 'triggers' that would result in their involvement being requested, so they are able to help inform if assistance is required.  If an onboard system is used to mitigate a risk originally classified as Major or above, the internal and external airworthiness experts will be specifically consulted.

    Coincidentally with,  but not as a result of, the accident, the risk assessment  process  and  methodology was moved from its location as Appendices B, C and D of CAP 722, into its own, self-contained document entitled “CAP 722A - Unmanned Aircraft System Operations in UK Airspace - Operating Safety Cases”; This move took place in July 2019 and some elements of content were updated at the time.  As a result, this recommendation is interpreted to apply to CAP 722A rather than the 'parent' CAP 722 document. 

    As a result of the introduction of the new UAS regulations, which became applicable on 31 December 2020, the CAA has been undertaking a wholesale update of CAP 722A to be published during Spring 2021.  The points relating to this recommendation will included in this update.

    The new edition of CAP 722A will also include the Specific Operations Risk Assessment (SORA) methodology, affirming the CAA's aim to meet safety objectives to continue to mitigate these risks.

    Update due

    January 2022

    CAA status

    Open - Tracked Actions 

    Recommendation text

    It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722, Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy, to provide guidance on the planning, completion and documenting of Radio Frequency surveys to reduce the risk of Radio Frequency interference or signal loss when operating Unmanned Aircraft Systems.

    Recommendation response

    The CAA accepts this recommendation:

    CAP 722A; Unmanned Aircraft Operations in UK Airspace - Operating Safety Cases; is the source document that provides guidance to applicants in the specific category on what should be included in an OSC that supports their application.  Guidance detailing possible methods to prove how robust a Command and Control (C2) link is will be provided and the potential efficacy of RF surveys will be highlighted, although the emphasis will be on the requirement for the applicant to prove and evidence a secure link. 

    As noted in the response to SR2021-002 above. CAP 722A has replaced the text that was previously contained within CAP 722's Appendices B, C and D; as a result, this recommendation is interpreted to apply to CAP 722A rather than the 'parent' CAP 722 document.

    As a result of the introduction of the new UAS regulations, which became applicable on 31 December 2020, the CAA has been undertaking a wholesale update of CAP 722A to be published during 2021.  The points relating to this recommendation will included in this update.

    Update due

    January 2022

    CAA status

    Open - Tracked Actions 

     

    Recommendation text

    It is recommended that the Civil Aviation Authority require Unmanned Aircraft System operators, that use unmanned aircraft which rely on a radio link to operate safety systems, to provide Radio Frequency survey reports to the Civil Aviation Authority for review, to ensure they are suitable and sufficient.

    Recommendation response

    The CAA partially accepts this recommendation:

    Following the advice to be published in response to SR2020-003 above, any RF surveys or similar produced must be made available to the CAA on request. The new UAS Regulations include a requirement for any documentation to be made available to the CAA on request. 

    If an RF survey has been stated as a mitigating factor to reduce the risk of a C2-related failure, or to support the use of an RF-enabled safety system as per this accident, then proof of example surveys will be required as part of the approval process.  Reference to RF surveys, methodology for conducting them, and their suitability as a safety mitigation has been added to the RPASST checklist for assessing audits.

    For other typical cases, the RPASST have added to their renewal assessment audit checklist an opportunity to request examination of example RF survey reports to check compliance.

    Update due

    January 2022

    CAA status

    Open - Tracked Actions

     

    Recommendation text

    It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722, Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy, with guidance on how to define an Unmanned Aircraft System's operational and safety areas, using up-to-date maps, accurate trajectory analysis and human or automated safety system reaction times, to ensure a safe operation.

    Recommendation response

    The CAA accepts this recommendation:

    The RPAS Policy Team (RPASPT) will introduce this in a future edition of either CAP 722 or one of its subordinate documents.

    Reference is already made in CAP722A to aeronautical charts and the AIP, and it makes clear that 'non-established' sites require an assessment for suitability; however, it does not make clear what a 'non-established' site is, and therefore when a site assessment is not required. Furthermore, it does not make clear that any digital imagery (Google maps etc) used must be verified as being correct, and that site layouts (particularly aerodromes) may change, since digital imagery was captured.

    The CAA will update CAP 722A to clarify these points and will ensure that these aspects are fully considered when assessing future risk assessments.

    CAP 722A provides limited guidance in regard to the use of trajectory estimation when determining the emergency buffer zone around the flight volume. The CAA will update CAP 722A with further guidance on this, and the inclusion of reaction times where manual systems are involved. The updated CAP 722A also introduces the concept of operational volume, and emergency buffer, including factors to take into account when determining their size.  The operational volume is the area within which the RPAS operation is planned to be contained within, while the emergency buffer is an extension to this area that may be used, but only in the event of a failure.

    Update due

    January 2022

    CAA status

    Open - Tracked Actions

     

    Recommendation text

    It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722; Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy, to require detailed evaluation of any Unmanned Aircraft Systems that use onboard systems to mitigate risks with a Risk Severity Classifications of 'Major', 'Hazardous' or 'Catastrophic'.”

    Recommendation response

    The CAA accepts this recommendation:

    The existing guidance on RPAS safety systems is included in CAP 722A Section 2, para 1.13.  This will be expanded during the rewrite occurring in early 2021.  The safety improvement provided by multiple, layered safety systems will be emphased.  Examples of some typical mass-market systems such as ballistic recovery systems will be included.

    Internal audit checklists referring to the technical volume of OSCs already required the auditor to assess whether any safety systems are appropriately installed and maintained. 

    Examples of some typical mass-market systems such as ballistic recovery systems will be included.

    Update due

    January 2022

    CAA status

    Open - Tracked Actions

     

    Recommendation text

    It is recommended that the Civil Aviation Authority introduce requirements to define a minimum standard for safety systems to be installed in Unmanned Aircraft Systems operating under an Operational Authorisation, to ensure adequate mitigation in the event of a malfunction.

    Recommendation response

    The CAA partially accepts this recommendation:

    The current OSC methodology in CAP722A for managing risk already considers operational and technical mitigations in the event of any failure or hazard and assesses whether they are appropriate.  Additionally, the RPASPT have pointed out that the CAA does not make regulations, this is the remit of DfT; their recommendation was that we consider the introduction of a policy that states we will adopt standards for UAS safety systems as they are developed and become available.

    However, due to the very wide range of possible operations within the Specific category, the use of 'safety systems' per se will not be necessary for every operational authorisation.

    As yet, no relevant minimum standards for the safety systems referred to in this recommendation have been defined; once the appropriate safety system standards have been are developed and become available, we will consider the introduction of an appropriate requirement where it is considered necessary. 

    Where the use of a safety system has been stated as a safety mitigating factor in a risk assessment, the minimum performance requirements of that safety system will be included as a condition of the resultant operational authorisation that is issued.

    Update due

    January 2022

    CAA status

    Open - Tracked Actions 

    Recommendation text

    It is recommended that the Civil Aviation Authority require Unmanned Aircraft System operations under an Operational Authorisation to be fitted with a data recording system which is capable of demonstrating: compliance with the Authorisation's conditions, safe operation and the logging of any failures which may affect the safe operation of the Unmanned Aircraft System.

    Recommendation response

    The CAA partially accepts this recommendation

    The RPASST checklists for initial audits include a requirement to check whether an applicant can measure and maintain the limitations they are applying for.  Where no direct metric (such as speed in m/s) is available, the authorisation will be written to reflect an example speed such as “a fast walking pace.”

    Due to the very wide range of possible operations within the Specific category, for which an operational authorisation is required, and the wide range of RPAS types that may be used, it would not be practicable, nor indeed proportionate, to require a data recording system to be fitted in every case.  It is for this reason that data recording is not mandated within the Specific category.

    Most of the smaller RPAS types that are on the market, and presently fill the majority of the specific category operations we see in the UK, have the ability to log some forms of operational data within the system.  But this is not generally a capability that can be activated, or subsequently installed, by the UAS operator.  In addition, it is already a condition of all operational authorisations that records of all operations are maintained for audit purposes.

    However, when considering the larger, more bespoke, RPAS types such as those that are similar to the subject of this accident, then it would be appropriate to require additional data recording capabilities to be included as the complexity of both the RPAS and the type of operation increases.  This will be covered within the revised CAP 722A document.

    Update due

    January 2022

    CAA status

    Open - Tracked Actions

     

    Recommendation text

    It is recommended that the Civil Aviation Authority specify the minimum requirements for the monitoring of Unmanned Aircraft System high-voltage stored energy devices, to ensure safety of operation.

    Recommendation response

    The CAA accepts this recommendation:

    The policy will need to be developed and included in a future guidance document.  The new airworthiness-focused Inspector on the RPASST will help with current assessments of battery use, carriage and storage for applications, and any application with “self-made” (i.e. non-COTS) batteries will be exposed to extra scrutiny. 

    In the meantime, an increased focus on this subject will be made during audits and any pre-authorisation assessment visits.

    Update due

    January 2022

    CAA status

    Open - Tracked Actions

     

    Recommendation text

    It is recommended that the Civil Aviation Authority specify the minimum requirements for readily identifiable warnings and safety information on Unmanned Aircraft high-voltage stored energy devices to inform 3rd parties of the potential hazard.

    Recommendation response

    The CAA accepts this recommendation

    These minimum requirements will require development and consideration of the most appropriate location for this guidance, either within the technical chapter of CAP 722, or in a separate document.

    In addition, this aspect would be required to be included within the risk assessment provided by the UAS operator and this will be covered within the revision to CAP 722A. An increased focus on this will be made during pre-authorisation assessments and, where appropriate, will be included as a condition of the operational authorisation.

    Update due

    January 2022

    CAA status

    Open - Tracked Actions

     

    Recommendation text

    It is recommended that the Civil Aviation Authority ensure that operators of Unmanned Aircraft Systems have an effective Safety Management System in place prior to issuing an Operational Authorisation.

    Recommendation response

    The CAA partially accepts this recommendation

    CAP 722 already covers elements of SMS that operators could use for best practice and to manage safety risks. 

    The regulation only states   a requirement for an SMS for Light UAS Certificate (LUC)approval holders under Part C UAS.LUC.030 of the Implementing Regulations for UAS. Due to the very wide range of possible operations within the Specific category for which an operational authorisation is required, it would not be practicable, nor indeed proportionate, to require every UAS operator to have a safety management system in place.

    The RPASST exercise a proportional, performance based approach to applications, and required that elements of an SMS such as functional reporting and investigation processes are included as the complexity of the RPAS and operation increase.

    Update due

    None

    CAA status

    Closed

     

    Recommendation text

    It is recommended that the Civil Aviation Authority, before issuing an Operational Authorisation to operate an Unmanned Aircraft System they have not previously had experience with, carry out a physical examination of the Unmanned Aircraft System to ensure that it is designed and built to suitable standards, and observe a test flight to confirm operation in accordance with the Operating Safety Case.

    Recommendation response

    The CAA partially accepts this recommendation:

    When considering larger, more bespoke RPAS types such as the subject of this accident, then this is the approach that will be taken.  However, in other cases, dependent on the type of operation that is being authorised, such an approach may prove to be impractical.

    Where any features of design and construction have been included as mitigations in any risk assessment, then it would be appropriate for a pre-flight physical examination and an observation of an initial test flight to be conducted (bearing in mind that any test flight also requires an Operational Authorisation to be issued).

    The RPASST will apply Performance Based Oversight (PBO) principles in order to target resource to risk.  When a new platform is used that is likely to attract a high risk score, it will be prioritised for both physical direct inspection from an airworthiness Inspector and a flight test depending on the likely requirements.  Even with COTS systems, the RPASST will use PBO to assess dynamically whether applications need a demonstration or test flight to show the requisite safety levels.  

    The RPASST also carry out sector-level reviews of risk metrics to help assess where PBO assets are best deployed.

    Update due

    None

    CAA status

    Closed

     

    Recommendation text

    It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722, Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy, to include reference to the consequences of not complying with the conditions of an Operational Authorisation to operate an Unmanned Aircraft System.

    Recommendation response

    The CAA accepts this recommendation

    The Air Navigation (Amendment) Order 2020 (SI 2020/1555) introduced a number of new articles into the Air Navigation Order 2016.  These create criminal offences, if the requirements of the UAS regulations that became applicable on 31 December 2020 are not complied with, along with the associated penalties.

    This amendment was explained in guidance for UAS users within CAP 2013 (published 17 December 2020) and has been included in amendment 2021/01 to CAP 722 Chapter 4, Section 4.1.3 (March 2021).

    Update due

    None

    CAA status

    Closed

     

    Recommendation text

    It is recommended that the Civil Aviation Authority adopt appropriate design, production, maintenance and reliability standards for all Unmanned Aircraft Systems with aircraft capable of imparting over 80 joules of energy.

    Recommendation response

    The CAA partially accepts this recommendation

    This is covered within the Delegated Regulation for Open Category UA and for the Specific Category work is ongoing within a number of standards bodies, including EUROCAE, ASTM and RTCA. The CAA will review standards as they become available and decide on the frameworks required to adopt these from a regulatory perspective.

    Update due

    January 2022

    CAA status

    Open - Tracked Actions

  • Recommendation text

    It is recommended that the Civil Aviation Authority requires all helicopters operating under a Police Air Operators Certificate, and first issued with an individual Certificate of airworthiness before 1 January 2018, to be equipped with a recording capability that captures data, audio and images in crash-survivable memory. They should, as far as reasonably practicable, record at least the parameters specified in The Air Navigation Order, Schedule 4, Scale SS(1) or SS(3) as appropriate. They should be capable of recording at least the last two hours of (a) communications by the crew, including Police Observers carried in support of the helicopter's operation, and (b) images of the cockpit environment. The image recordings should have sufficient coverage, quality and frame rate characteristics to include actions by the crew, control selections and instrument displays that are not captured by the data recorder. The audio and image recorders should be capable of operating for at least 10 minutes after the loss of the normal electrical supply.

    Recommendation response

    The CAA accepts this recommendation and, subject to an impact assessment and liaison with the police operators, will require all helicopters operating under a Police Air Operators Certificate with a maximum take-off mass (MTOM) of more than 2,730 kg and first issued with an individual Certificate of Airworthiness before 1 January 2018, to be equipped with a recording capability that captures data, audio and flight deck images in crash-survivable memory. In order to put any change into effect, the CAA will need to amend General Exemption E4111 for the fitment of recorders to helicopters with a MTOM between 2,730 and 3,175 kg and the requirements for police helicopters with a MTOM greater than 3,175 kg. The CAA will work with the affected operators to agree a means of compliance for individual types in line with ICAO standards and recommended practices and ensure that appropriate protection provisions are afforded for image recordings. The CAA will also review, and amend as necessary, associated CAPs and CAA Specifications, for flight recorders. Introduction of amended requirements is expected to be completed by 3rd Quarter 2016.

    Recommendation response update May 2021

    The AAIB Safety Recommendations 2015-032 and 033 recommended that the CAA require certain helicopters operating under a Police Air operator Certificate to be fitted with flight recorders including cockpit image recorders (airborne image recorder (AIR)).  Additionally, SR 2015-034 recommended that the CAA consider requiring State aircraft not already covered by SR 2015-032 and 033 to be fitted with flight recorders, including cockpit image recorders.  

    The CAA conducted a focused consultation in 2016 with Police and SAR operators considering the various options for all the SRs and determined the way forward cognisant also of the feedback from industry. In response to SR 2015-034 specifically, it was decided not to pursue changes to State aeroplane equipment requirements but that it would be appropriate to align the requirements and meet the safety intent of the SRs for all State helicopters. The State SAR helicopters under contract with the UK Maritime Coastguard Agency (MCA) were already required to be equipped with FDR/CVR and therefore the alignment was limited to the fitment of airborne image recorders.

    To implement the necessary requirements, the CAA issued Safety Directive 2016-006 detailing the type and level of equipment to be fitted to current and future helicopters operating as State aircraft.  CAA Specification 23 was also introduced to provide detailed information on the technical requirements for the equipment and fitting.  However, due to some difficulties experienced by the operators in procuring and fitting the equipment, the compliance dates had to be extended and SD 2018-002, now superseded by 2020-001, were issued.  The operators are now meeting the following equipment requirements mandated by the SD:

    1. Helicopters with an individual Certificate of Airworthiness first issued before 1 January 2019 shall from 1 August 2021. 

    (a) for those with a maximum take-off mass (MTOM) of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A airborne image recording system (AIRS) except those which have a Class C AIRS; or 

    (b) for those with a MTOM more than 3,175 kg, be fitted with a Class A airborne image recorder (AIR). 

    2. Helicopters with an individual Certificate of Airworthiness first issued on or after 1 January 2019 shall: 

    (a) for those with a MTOM of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A AIRS; or 

    (b) for those with a MTOM more than 3,175 kg, be fitted with a Class A AIR.

    The CAA will incorporate these requirements into amendment of the scales of equipment for such operations in the Air Navigation Order at the next suitable opportunity.  Once done, this will provide for the SD to be revoked. 

     

    Update due

    June 2022

    CAA status

    Open - Tracked Actions

    Recommendation text

    It is recommended that the Civil Aviation Authority requires all helicopters operating under a Police Air Operators Certificate, and first issued with an individual Certificate of Airworthiness on or after 1 January 2018, to be fitted with flight recorders that record data, audio and images in crash-survivable memory. These should record at least the parameters specified in The Air Navigation Order, Schedule 4, Scale SS(1) or SS(3), as appropriate. They should be capable of recording at least the last two hours of (a) communications by the crew, including Police Observers carried in support of the helicopter's operation, and (b) cockpit image recordings. The image recordings should have sufficient coverage, quality and frame rate characteristics to include control selections and instrument displays that are not captured by the other data recorders. The audio and image recorders should be capable of operating for at least 10 minutes after the loss of the normal electrical supply.

    Recommendation response

    The CAA accepts this recommendation and, subject to an impact assessment and liaison with the police operators, will require all helicopters operating under a Police Air Operators Certificate and first issued with an individual Certificate of Airworthiness on or after 1 January 2018, to be equipped with a recording capability that captures data, audio and images in crash-survivable memory. To achieve this in the suggested timescale, the CAA will consider making a Direction to that effect but will also, as part of a wider review of the Air Navigation Order (ANO), prepare amendments to the flight recorder requirements that align with ICAO standards and recommended practices and European standards including the appropriate protection provisions for image recordings. The CAA would anticipate this change being addressed within the planned 2016 ANO amendment cycle.

    Recommendation response update May 2021

    The AAIB Safety Recommendations 2015-032 and 033 recommended that the CAA require certain helicopters operating under a Police Air operator Certificate to be fitted with flight recorders including cockpit image recorders (airborne image recorder (AIR)).  Additionally, SR 2015-034 recommended that the CAA consider requiring State aircraft not already covered by SR 2015-032 and 033 to be fitted with flight recorders, including cockpit image recorders.  

    The CAA conducted a focused consultation in 2016 with Police and SAR operators considering the various options for all the SRs and determined the way forward cognisant also of the feedback from industry. In response to SR 2015-034 specifically, it was decided not to pursue changes to State aeroplane equipment requirements but that it would be appropriate to align the requirements and meet the safety intent of the SRs for all State helicopters. The State SAR helicopters under contract with the UK Maritime Coastguard Agency (MCA) were already required to be equipped with FDR/CVR and therefore the alignment was limited to the fitment of airborne image recorders.

    To implement the necessary requirements, the CAA issued Safety Directive 2016-006 detailing the type and level of equipment to be fitted to current and future helicopters operating as State aircraft.  CAA Specification 23 was also introduced to provide detailed information on the technical requirements for the equipment and fitting.  However, due to some difficulties experienced by the operators in procuring and fitting the equipment, the compliance dates had to be extended and SD 2018-002, now superseded by 2020-001, were issued.  The operators are now meeting the following equipment requirements mandated by the SD:

    1. Helicopters with an individual Certificate of Airworthiness first issued before 1 January 2019 shall from 1 August 2021. 

    (a) for those with a maximum take-off mass (MTOM) of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A airborne image recording system (AIRS) except those which have a Class C AIRS; or 

    (b) for those with a MTOM more than 3,175 kg, be fitted with a Class A airborne image recorder (AIR). 

    2. Helicopters with an individual Certificate of Airworthiness first issued on or after 1 January 2019 shall: 

    (a) for those with a MTOM of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A AIRS; or 

    (b) for those with a MTOM more than 3,175 kg, be fitted with a Class A AIR.

    The CAA will incorporate these requirements into amendment of the scales of equipment for such operations in the Air Navigation Order at the next suitable opportunity.  Once done, this will provide for the SD to be revoked. 

     

    Update due

    June 2022

    CAA status

    Open - Tracked Actions

    Recommendation text

    It is recommended that the Civil Aviation Authority considers applying the requirements of AAIB Safety Recommendation 2015‑032 and AAIB Safety Recommendation 2015-033 to State aircraft not already covered by these Safety Recommendations.

    Recommendation response

    The CAA accepts this recommendation and will consider whether the requirements of AAIB Safety Recommendation 2015-032 and AAIB Safety Recommendation 2015-033 should be applied to civil registered State aircraft not already covered by these Safety Recommendations and in particular the suitability of the introduction and/or retrofitting of image recorders. Due to their size, all current civil Search and Rescue helicopters are fitted with flight data recorders and cockpit voice recorders. The CAA anticipates determination of this issue by 3rd Quarter 2016.

    Recommendation response update May 2021

    The AAIB Safety Recommendations 2015-032 and 033 recommended that the CAA require certain helicopters operating under a Police Air operator Certificate to be fitted with flight recorders including cockpit image recorders (airborne image recorder (AIR)).  Additionally, SR 2015-034 recommended that the CAA consider requiring State aircraft not already covered by SR 2015-032 and 033 to be fitted with flight recorders, including cockpit image recorders.  

    The CAA conducted a focused consultation in 2016 with Police and SAR operators considering the various options for all the SRs and determined the way forward cognisant also of the feedback from industry. In response to SR 2015-034 specifically, it was decided not to pursue changes to State aeroplane equipment requirements but that it would be appropriate to align the requirements and meet the safety intent of the SRs for all State helicopters. The State SAR helicopters under contract with the UK Maritime Coastguard Agency (MCA) were already required to be equipped with FDR/CVR and therefore the alignment was limited to the fitment of airborne image recorders.

    To implement the necessary requirements, the CAA issued Safety Directive 2016-006 detailing the type and level of equipment to be fitted to current and future helicopters operating as State aircraft.  CAA Specification 23 was also introduced to provide detailed information on the technical requirements for the equipment and fitting.  However, due to some difficulties experienced by the operators in procuring and fitting the equipment, the compliance dates had to be extended and SD 2018-002, now superseded by 2020-001, were issued.  The operators are now meeting the following equipment requirements mandated by the SD:

    1. Helicopters with an individual Certificate of Airworthiness first issued before 1 January 2019 shall from 1 August 2021. 

    (a) for those with a maximum take-off mass (MTOM) of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A airborne image recording system (AIRS) except those which have a Class C AIRS; or 

    (b) for those with a MTOM more than 3,175 kg, be fitted with a Class A airborne image recorder (AIR). 

    2. Helicopters with an individual Certificate of Airworthiness first issued on or after 1 January 2019 shall: 

    (a) for those with a MTOM of more than 2,730 kg but not more than 3,175 kg, be fitted with a Class A AIRS; or 

    (b) for those with a MTOM more than 3,175 kg, be fitted with a Class A AIR.

    The CAA will incorporate these requirements into amendment of the scales of equipment for such operations in the Air Navigation Order at the next suitable opportunity.  Once done, this will provide for the SD to be revoked. 

     

    Update due

    None

    CAA status

    Closed


  • Accident N264DB

    N264DB - Piper PA-46-310P Malibu (nr Guernsey)

    AAIB Report: Piper PA-46-310P Malibu, N264DB, 21st January 2019

  • Recommendation text

    It is recommended that the Civil Aviation Authority ensure that the system in place to meet the requirements of EASA Part ARA.GEN.220 is effective in maintaining accurate and up-to-date records related to personnel licences, certificates and ratings.

    Recommendation response

    The Civil Aviation Authority accepts this Recommendation. A review of the current system is underway for ensuring licence records held by the Authority are updated following any changes related to personal licences, certificates and ratings to ensure the requirements of EASA Part ARA GEN.220 are met. We intend to complete this review by October 2020 with recommendations implemented by January 2021. Please note that this timeline may be affected by operational changes required as a result of COVID19 contingency plans.

    In addition, the CAA has and continues to remind examiners of their responsibility to submit the required examination documentation to the Authority within 14 working days from the skill test, proficiency check or assessment of competence.

    Recommendation update: 12/07/2021

    The CAA has reviewed its processes for maintaining and updating records related to personnel licences, certificates and ratings. CAA are recruiting additional resources to maintain accurate and up to date individual records. The additional measure of assessing these documents will continue to ensure we always give the correct information. We believe this addresses the intent of the recommendation. 

    The “Aviation Licensing Discovery” activity will still be planned for a later date and should provide a more enhanced solution for personnel licensing. The CAA are currently focused on improving the quality of existing application forms by moving more forms from paper to online.

    Update due

    None

    CAA status

    Closed 

     

    Recommendation text

    It is recommended that the Civil Aviation Authority require piston engine aircraft which may have a risk of carbon monoxide poisoning to have a CO detector with an active warning to alert pilots to the presence of elevated levels of carbon monoxide.

    Recommendation response

    "The Civil Aviation Authority does not currently accept this Recommendation, however we will revisit this position at the conclusion of our operational trial of carbon monoxide detectors.

    We are considering what barriers in addition to good design and maintenance practice will be both effective in further minimising the likelihood of critical CO contamination in the UK GA fleet, whilst acknowledging that any such additional measures should be both practical and proportionate. 

    On 3 March 2020, we published a Safety Notice, CAA SN 2020/003, which highlights the potential benefits of carrying low cost available commercial/domestic active detectors, as well as conventionally installed, approved aviation units.  We will further advertise this Safety Notice through communication to all pilots when the current restrictions on recreational flying due to COVID-19 are lifted, to reduce the risk of this announcement being overlooked. Importantly, the Safety Notice includes reference to a CAA-sponsored carriage trial of low-cost, widely available units which we see as facilitating informed decisions in the future regarding recommending (or possibly mandating) specific categories of devices. This trial  will establish if there are any negative safety implications (such as loose article hazard or distraction) associated with the carriage of carbon monoxide detectors. However, given the implications of COVID-19 on the 2020 flying season and stakeholder events, the timing for this trial is currently under review.

    Recommendation update: 12/07/2021

    The CAA recognises the risk identified by the AAIB and is therefore conducting an operational trial of active CO detectors. The CAA will use the trial to assess the safety and practical implications of carrying active CO detectors onboard general aviation aircraft and expects to publish a report on the outcomes and findings of the trial in February 2022. The trial was originally scheduled to start in December 2020 but was delayed due to restrictions from COVID-19.

    In the meantime, the CAA is taking the following steps:  
    SN-2020/003 has been updated (published April 30th 2021) to reflect the latest status of the CO detector trial and to reference the specific CO concentration check included in the Minimum Inspection Programme of    UK Reg (EU) No 1321/2014 Annex Vb (Part-ML). 
    A Safety Sense Leaflet dedicated to carbon monoxide detection and prevention is being developed and will be published after the trial concludes to reflect the latest information and recommended practices. A further update will be provided when the trial report is published.

    Update due

    March 2022

    CAA status

    Open - Tracked Actions

  • Recommendation text

    Improve the working processes to assess operational risks of newly declared EASA Part-SPO operators, and to verify continued compliance with the applicable requirements in accordance with EASA Air OPS ARO.GEN.300 Oversight (a)(2).

    Recommendation response

    The UK CAA accepts this recommendation. The UK CAA will carry out a full review of the SPO oversight process, procedures and policy and will carry out a review of SPO accountabilities (across multiple teams). The date set to accomplish both reviews is set for 31 December 2020. Following the outcome of the aforementioned reviews, the UK CAA will implement changes to; accountabilities, process, procedures and policy with the aim of Improving the working processes to assess operational risks of newly declared EASA PartSPO operators, and to verify continued compliance with the applicable requirements in accordance with EASA Air OPS ARO.GEN.300 Oversight (a)(2). The date set to implement the changes is set for 30 April 2021.

    Response update: 24/06/21

    The UK CAA carried out a full review of the SPO oversight process, procedures and policy and a review of SPO accountabilities (across multiple teams). The date set to accomplish both reviews was set for 31 December 2020. Following the outcome of the aforementioned reviews, the UK CAA will implement changes to; accountabilities, process, procedures and policy with the aim of improving the working processes to assess operational risks of newly declared EASA Part-SPO operators. The improvements to compliance with the applicable requirements will be embedded within the new processes ensuring a more risk-based approach to SPO and better clarity on continued oversight requirements.  

    The original date set to implement the changes was set for 30 April 2021, we are now sequencing this activity alongside overseeing industry restart as Covid-19 restrictions ease in the UK, so the changes will now be implemented by 31 July 2021.

    Response update: 20/09/21

    The improvements described in our previous update have now been developed and embedded within our processes and procedures, ensuring a timely assessment of newly declared Part-SPO operators and a documented approach to risk-based oversight.

    Update due

    None

    CAA status

    Closed

    Recommendation text

    Conduct a baseline assessment of the operational risks, and a thorough compliance and safety audit of FCSL's safety management system, flight operations, pilot training, weight and balance procedures, and documented procedures for calibration flights.

    Recommendation response

    The UK CAA accepts this recommendation. The scope of the next Part-SPO audit conducted by the UK CAA, which it is anticipated will be completed by the 30 September 2020, will focus on a baseline assessment and a thorough compliance and safety audit of FCSL's Safety Management System, flight operations, pilot training, weight and balance procedures, and documented procedures for calibration flights.

    Response update: 28/10/20

    The CAA completed an on-site audit at Shoreham Airport with Flight Calibration Services Limited on 8th August 2020, producing a baseline assessment of the operator. Conducting a compliance audit of the operator's SPO operations focusing on the Safety Management System, flight operations, pilot training, weight and balance procedures, and a review of the documented procedures for calibration flights.

    A satisfactory review of previous inspection reports was also carried out, verifying evidence and supporting documentation of any remedial actions.

    The CAA conducted a review in conjunction with the requirements set out in (EU)965/2012. Specifically, a review of the requirements for operational oversight as detailed in Part-ARO and those requirements set out in Part-ORO and Part-SPO.

    As a result of the above audit activity the CAA is satisfied that the Safety Management System, Training, Operations and associated procedures meet the requirements of FSCL's operation. 

    Response update: 24/06/21

    The CAA completed an on-site audit at Shoreham Airport with Flight Calibration Services Limited on 8th August 2020, producing a baseline assessment of the operator. Conducting a compliance audit of the operator's SPO operations focusing on the Safety Management System, flight operations, pilot training, weight and balance procedures, and a review of the documented procedures for calibration flights.

    A satisfactory review of previous inspection reports was also carried out, verifying evidence and supporting documentation of any remedial actions.

    The CAA conducted a review in conjunction with the requirements set out in (EU)965/2012. Specifically, a review of the requirements for operational oversight as detailed in Part-ARO and those requirements set out in Part-ORO and Part-SPO.

    As a result of the above audit activity the CAA is satisfied that the Safety Management System, Training, Operations and associated procedures meet the requirements of FSCL's operation.  

    CAA status

    Closed


  • Airprox RV12/P68

    Vans RV12 & Partenavia P68 B (nr Chatteris)

    AIRPROX REPORT No 2019201

  • Recommendation text

    The CAA to consider mandating additional cockpit crew to enable enhanced lookout for single-pilot survey operations.

    Recommendation response

    Whilst the CAA recognises the desired safety outcome, there are significant barriers to the CAA accepting this in its current form. The recommendation does not recognise where the ownership for this hazard of SPO operations and associated lookout risks lie. We must be clear about the respective roles of regulator and the regulated entity.
    It is the CAA's role to assure itself that risk is assessed, and the associated mitigating actions are robust. This assurance is conducted through an assessment of the operator's operations manual under which all flights should be conducted. ORO.GEN.110 sets out clearly the responsibilities of the Operator to ensure safe conduct of any flight and it is against this regulation that the test is applied.

    Managing an effective lookout in any aircraft is the responsibility of the pilot in command following guidance issued by the operators concerned and stipulated in the Operations Manual. The AMC of EASA part SPO states:
    SOPs should be based on a systematic risk assessment to ensure that the risks associated with the task are acceptable. The risk assessment should describe the activity in detail, identify the relevant hazards, analyse the causes and consequences of accidental events and establish methods to treat the associated risk.

    It is the operator's responsibility to conduct this assessment task and the risks presented may be different dependent on the nature of the operation and the geographical area.

    We recognise the unique hazard of the operations in question and therefore, in response to the recommendation, confirm that the CAA Partially Accepts this recommendation and will conduct a review of the risk assessments of survey operators, to ensure they meet the requirements of AMC SPO.OP.230(b) and are robust in addressing this risk.

    Response update: 19/01/2021

    In conjunction with a Safety Recommendation from the Accident Report into G-MDME which was operated by a Part SPO organisation, the CAA has conducted a review of the implementation of Regulation (EU) 965/2012 Part Specialised Operations (SPO).  The review also considered Aerial work through a Foreign Carrier Permit (FCP) against Article 252[1] of the Air Navigation Order and arrangements for Unmanned Air Systems (UAS) as detailed in CAP722A.

    The CAA will now consider the findings and recommendations of the review to determine the preferred option and the work needed to be undertaken to put any changes into effect.

    The CAA Flight Ops department conducted a review of operator's risk assessment with particular emphasis on MAC mitigations and single pilot operations through a Special Objective Check. 57 operators have declared that they conduct survey operations, and a review of their operational Safety Assessment and associated mitigations has started under the auspices of the CAA SPO working group. The Impact of the EU withdrawal and Covid alongside recovery activity means that it is likely the original planned completion for this work (end of March 2021) will be missed. We expect to be able to complete the activity by 30th June 2021, when we will be in a position to report on the adequacy of Survey Operators risk assessments. 

    Response update: 09/08/21

    The CAA has considered the findings and recommendations of our review on the implementation of Retained UK Regulation (EU) 965/2012 Part Specialised Operations (SPO) and, through the SPO Governance Group, has conducted targeted Safety Case assessments of involved operators.

    It has been agreed that the addition of cockpit crew may form part of an operator's mitigation to the risk of mid-air collision, where the operating environment is assessed as presenting this particular risk, however it would be inappropriate to mandate it for all single pilot operations. The risk is the Operator`s responsibility to manage, the management of these risks being overseen by the UK CAA through established processes. Where a risk is considered relevant it would require the appropriate level of mitigations to manage the risk to an acceptable level. The addition of a second cockpit crew into a single pilot operation could add additional risks which would also need mitigating. In addition, the qualification and responsibilities of the second crew would need defining in the risk assessment so as ensure that the overall risk was reduced in the new safety case.

    Should an operator's risk management and safety case support the additional cockpit crew to mitigate the risk, we would support this.

    Additional information:
    Following analysis of operator feedback, it seems that although a number of organisations may offer survey work as part of their portfolio, not many undertake the activity. Part CAT operators have their safety cases reviewed as part of normal oversight activities (including evidence that it is being used and effective) and covered in PBO Internal Review Meeting (IRM) discussions. Evidence so far is that CAT operators are aware of the hazards and have put mitigations in place. 

    Part NCC organisations that perform such activity have had their oversight frequency and focus reviewed. 

    The processes for including survey operators' risk assessment for single pilot work is now embedded in Flight Operations oversight, adequately captured in SARG procedures therefore it is now considered as BAU.

    CAA Status 

    Closed 


  • Airprox S76/DCH6

    Sikorsky S76 & De Havilland DCH6 100 (nr Wisbech)

    AIRPROX REPORT No 2018185  

  • Recommendation text

    The CAA review current regulation concerning RLLCs.

    Recommendation response

    The CAA is still reviewing current RLLC regulations, particularly with reference to civilian pilot responsibility. The CAA have been engaged with the DfT, Royal Household and TQHF to provide improvement in this area since March this year. Due to several factors including BREXIT and additional requests from the Royal Household this has resulted in a lengthy process to ensure correct measures are taken moving forward. The CAA is committed to undertaking this review correctly and ensuring any future change, if agreed, is implemented appropriately and without any ambiguity.

    Response update: 17/08/21

    Further to the response on the 18 December 2019 the CAA have been conducting a review of the Royal Low-Level Corridor (RLLC) regulations. Over the last 10 months the CAA have been liaising with The Queen's Helicopter Flight (TQHF) and representatives of the Military Aviation Authority (MAA). This was aimed at understanding the specific requirement and consider these against the current regulations and the recommendations with in the Airprox Report 2018185.

    When considering the Airprox Report 2018185, alongside the recommendation for the CAA to review the RLLC regulations the report also highlighted 3 points which have been drawn out to help inform the review.

    1. Differences between current regulations place military controllers  in a position of having to apply separation standards between military aircraft and the Royal Flight and not having to provide separation between civilian aircraft and the Royal Flight.
    2. Regulations for Royal Flights were split across three documents, UK Aeronautical Information Publication (AIP), Aeronautical Information Circular (AIC)1 and MAA Regulatory Article (RA) 3237 causing complexity and confusion.
    3. Existing Regulations where not SERA compliant 'Members agreed that, for RLLCs, the AIC and UK AIP both implied that the onus on not flying into proximity with a Royal Helicopter flight rested entirely on the other pilot, whereas, under SERA this was not the case where Exempting Royal Helicopter Flights from SERA requirements would not be appropriate'.

    Noting points raised within the Airprox report, the review has determined there is an on-going demand to support TQHF operations. There is however an additional emergent requirement to provide greater protection for flights carrying Her Majesty, where these flights cannot be conducted in existing Controlled Airspace (CAS). Significant work has been undertaken to determine the appropriate airspace structure to support this requirement. Due to variable nature of the tasking combined with the lack of existing CAS or available air traffic provision, Restricted Airspace provides the only viable option to provide the level of protection required.  Owing to the nature of Restricted Airspace this will need to be notified via NOTAM in a timely fashion, where each routing will require consideration to ensure safety to airspace users.  Due to the pandemic and the associated reduction on Royal travel the exact process for this is still within a trial phase in order to establish the exact process for ensuring timely relevant notification of these Restrictions.

    For all other Royal Flights, it would not be practicable or appropriate to establish Restricted Airspace. Given this constraint and due to wider considerations beyond airspace, TQHF would not want to notify these flights via NOTAM; instead wishing to provide advance notice to selected entities only, principally the military. This is a balanced determination taking into consideration the number, type, and locations of military activity. This utilise the issuing of a 'signal' addressed to predominantly military units only, where the signal is forwarded internally within those units to the relevant entities. The practice of using a NOTAM to notify RLLC was adopted in 2018 but ultimately withdrawn that year with the withdrawal of the AIC cited in the Airprox report, reverting to the signal process. Work is currently underway to support the further improvement of this signal process by providing an automated generation of a visual representation of the routing alongside the standard signal text. This upgrade is currently being trialed and subject to feedback is expected to be adopted later this year. 

    When considering applicability of RLLC to civilians, it is not possible to apply separation criteria without the establishment of a notified 'structure', such as CAS/TMZ. It would therefore not be appropriate or possible to expect civilian operators to assume a greater level or responsibility toward ensuring collision avoidance. Civilian pilots and controllers should discharge their responsibilities in accordance with the airspace. Noting this point the civilian Aeronautical Information Publication (AIP) has been amended since the Airprox, removing the unintended implication, and re-enforcing the applicability of RLLC to the military only, placing no obligation on civilian controller or pilot. Ultimately TQHF operate in accordance with the background classification of airspace and are not exempted from SERA requirements.

    The Military MAA Regulatory Article (RA) 3237, outlines the regulations relating to RLLC, this RA still however includes the reference to civilian aircraft. TQHF have requested the MAA review RA3237 where this review is expected to occur in the coming months.  Alongside the review the CAA will request the reference to the civilian aircraft is removed from the RA. On completion of the MAA review the civilian AIP entry will be amended to reference the RA3237 only, removing the split of information across documents. Therefore, addressing point 2 and 3 above where point 1 will be considered more widely within the upcoming MAA review.

    More broadly the review has identified TQHF maintain the requirement for the RLLC where there is a further requirement for added protection when carrying Her Majesty.  We remain engaged with TQHF and the MAA were work is continuing to refine both the timely establishment of Restricted Airspace, the processes regarding the current 'notification' of RLLC and to contribute to the MAA review of RA3237.

    CAA Status

    Closed