SAFER recommendation management

Recommendation text

a. Coordinate with the Federal Aviation Authority to request an update to Technical Standard 135 by the Parachute Industries Association, in order to ensure clarity of the requirements of the standard.
b. Coordinate with the Federal Aviation Authority to either, request an update to the Federal Aviation Authority Technical Standard Order C23f, or consider the issue of a UK Technical Standard Order Authorisation (UKTSOA) to require parachute assembly manufacturers to provide evidence of gap analysis of safety critical parachuting equipment manufactured under obsolete standards.

Update Due

17 October 2023

CAA Status

Open - Initial Response

Recommendation text

That JHC, HQAC, RNHQ and the CAA refresh publicity regarding the hazard associated with rotor downwash on low-mass air vehicles.

Update Due

January 2023

CAA Status

Open - Initial Response

Recommendation text

The CAA facilitates the production of a consolidated data file, in a suitable electronic format, which permits the display of published Instrument Approach Procedures for aerodromes in Classes E, F and G airspace on moving map devices.

Initial response

The CAA accepts this recommendation from the UK Airprox Board.

The CAA is working in collaboration with the UK AIS to deliver all digital datasets required by UK legislation (UK Reg (EU) 2017/373) and specified in ICAO Annex 15. This also includes Instrument Flight Procedure (IFP) datasets provided in AIXM data exchange format.

In addition to the specified ICAO derived digital datasets, the CAA created a list of additional UK-specific datasets which the UK AIS has also been requested to deliver as part of the same implementation process. One of those additional datasets, an ICAO IFP Approach Chart Data Subset, to be provided as a separate subset (2D or 3D KML output), or part of a wider AIP Google Earth Data Subset, will directly address the UKAB Recommendation.

The target date for all IFP-related tasks in this dataset workstream is for completion by the end of 2024, which takes into account the time necessary to develop the required enhancements in digital data exchange format and to review the associated costs to ensure that the necessary funding is in place.
To ensure the successful implementation of this safety recommendation we also seek UKAB support to the CAA’s efforts. The CAA request that the UKAB considers making two additional recommendations in relation to Airprox 2022030.

Based on the information provided in the Airprox 2022030, it appears that the information about the Instrument Approach Procedure to RWY 19 at EGTK was available to the glider pilot (VFR charts depict the IAP using the standard “feathers” symbol with an instruction to contact the aerodrome ATSU). The Skyway Code also advises VFR traffic that when operating near aerodromes with an IAP depicted by the “feathers” symbol they should avoid crossing them unless talking to the relevant ATSU. It seems the pilot did not avoid the area, nor did they follow the correctly published advice to contact the aerodrome ATSU. It seems necessary to address pilot awareness and education. As a minimum, it would be beneficial to ensure that pilots know how to use Aeronautical Information Products (UK AIP, AIP Supplements, AICs, NOTAM, charts and datasets delivered by the UK AIS) and also aeronautical data provided by data services providers before and during their flight. The CAA published a Safety Sense Leaflet “VFR Moving Map Devices”, which sets out the minimum levels of proficiency GA pilots should have when using a moving map as well as covering the benefits and common issues.

The other mitigant would be a recommendation addressed directly to third party providers i.e. uncertified providers of aeronautical data for use on aircraft, to follow the guidance in CAP779 and process the data in an appropriate manner, which meets the airspace end-users' requirements and allows for safe navigation operations (although not used as the sole or primary means of navigation). When processing aeronautical information sourced from UK Aeronautical Information Products, they should apply best practices to ensure that it maintains its integrity, is timely, complete and in a form suitable for users (see CAP779, Chapter 1, Paragraph 1.35). It may also be worth noting that risks relating to 3rd party products and services (mainly moving maps) are already identified on the CAA Risk Register and we are currently working to mitigate these risks including educational activities, guidance materials and the consideration of potential regulatory mechanisms to enable the CAA to exert more influence over third-party providers in relation to data quality. A recommendation from the UKAB to third party providers would assist the CAA’s work to mitigate these risks.
In conclusion, it is the CAA’s view that whilst delivery of IFP Data Sets will help to mitigate the identified risk, the value of data sets would be greatly enhanced by improvements in the use of UK Aeronautical Information Products by pilots and third-party providers. We ask the UKAB to consider including the two additional recommendations in relation to Airprox 2022030, one aimed at pilots and the other at third-party providers.

Update Due

01/06/2024

CAA Status

Open - Tracked actions

Recommendation text

It is recommended that the UK Civil Aviation Authority, in conjunction with other regulatory authorities, develop a set of technical specifications and, subsequently, develop certification standards for an on-board system that will alert the crew of an aircraft to abnormally low acceleration during takeoff.

Initial response

The UK CAA accepts this Safety recommendation.

In order to ensure any UK position is coordinated with other key aviation regulatory bodies, we have started engagement to determine what, if any, parallel workstreams are already in process. We have also started engagement with Organisations developing standards for Aviation Equipment to understand if they have already been approached to work towards an agreed MOPS for any design solution. Any future mandate that is associated with agreed technical specifications will require further consultation – ideally with a coordinated regulatory action.

A workshop with key UK airlines is planned for Q1 2023 to start the initial scope of a technical solution. This will be followed by OEM meetings and further regulator outreach to try and maintain common collective position. The consequences and viability of a UK only approach will have to be considered in due course if a more global consensus is not possible.

Update: August 2023

The UK CAA, through our Design and Certification department, has been investigating any previous work into the development to monitor dynamic take-off performance with the ability to warn the pilot.

The UK CAA has discussed the development in this area with the FAA and EASA; whilst we do not believe either of these authorities are engaged in any certification activity of dynamic take-off monitoring, they both recognise the risk and have both positively engaged with us.

In addition, the UK CAA presented this topic at the FAA InfoShare, where contact was made with US airlines, regulators, and OEMs. Following this, we have had a workshop with Southwest Airlines that have shared their algorithms, and a follow-up with Boeing Safety team to discuss Boeing activities to find mitigations for this type of event. These are ongoing relationships; the UK CAA are facilitating a link for UK B737 operators directly with Southwest safety department.

The UK CAA has recently written to EUROCAE, requesting that a proposal be tabled at the next council meeting or Technical Advisory Committee to consider re-opening this working group to prepare MOPS / MASPS, which could ultimately form the basis of regulatory action that could reduce the number of take-off performance events.

Update Due

29 February 2024

CAA Status

Open - Tracked actions

Recommendation text

It is recommended that the UK Civil Aviation Authority encourage all UK Air Operator Certificate holders to implement into their flight data monitoring programme algorithms to detect the precursors relevant to the monitoring of takeoff performance detailed in the European Operators Flight Data Monitoring Document, Guidance for the implementation of flight data monitoring precursors.

Initial response

The UK CAA accepts this Safety recommendation.

The UK CAA recognises that the identification of the correct threat line, which could lead to a runway excursion event, is an important part of any safety risk mitigation strategies for the Take-off Performance errors.

The UK CAA will seek to maximise the safety benefit of the FDM programmes by

• Identifying FDM events that can be easily linked to take-off performance errors as ‘precursors’ to the undesired outcome (runway excursion).
• Agree on common trigger values that could be used to produce a wider data set to identify sector risks to share with all operators, subject to confidential protocols being agreed and accepted.
  We plan to do this by working with large AOC organisations through dedicated workshops and publish FDM ‘best practice considerations’ by the end of 2023.

Update: August 2023

The CAA wrote to key airlines in December 2022 describing the safety concern and the activities we are considering. The letter contained information on current reliance on the human barrier to avoid the safety risk manifestation, and potential to use FDM data to detect the precursors or undetected events. The letter was well-received, and all agreed to support any associated initiatives.

The CAA hosted a preliminary workshop for the main airlines in January 2023, which introduced the CAA Bow Tie and barriers/controls. The workshop agreed an FDM workstream would be launched to determine what common markers could be used to ‘measure’ the size of the safety concern, and potentially identify unknown ‘near-misses’.

Other UK airlines are also active in investigating FDM potential to measure reduced performance margins. The various FDM threads will be brought together via the FDM group, including possible amendments to CAP739.

Update Due

29 February 2024

CAA Status

Open - Tracked actions

Recommendation text

It is recommended that the Civil Aviation Authority review the use of magnetic tape flight data recorders used in aircraft operated by UK Air Operator Certificate holders and establish if there is a practical way to comply with the ICAO requirement to cease their use.

Initial response

Airworthiness have carried out a survey of prominent UK operators and none of the responses received indicate use of magnetic tape flight data recorders. We will review the existing regulation CAT.IDE. A.190 & CAT.IDE. H.190 (Compliant with EUROCAE ED-112) for flight data recorders and consider if a change to the existing regulations are required to align with Cockpit Voice Recorders.

Update: August 2023

A review of regulations CAT.IDE. A.190 & CAT.IDE. H.190 (Compliant with EUROCAE ED-112) for flight data recorders has been carried out. A new policy mandate has been submitted to the UK CAA policy department to update both regulations with an additional line (f) to include: (f) By 1 January 20XX at the latest, the FDR shall record on means other than magnetic tape or magnetic wire. This will bring both regulations in line with the CVR, CAT.IDE.A.185 and comply with the ICAO requirement.

Update Due

23 October 2023

CAA Status

Open - Tracked actions

Recommendation text

It is recommended that the Civil Aviation Authority require that magnetic tape flight data recorders, used in aircraft operated by UK Air Operator Certificate holders, comply with the Civil Aviation Authority Specification No 10, regarding the error rate requirements, by checking the complete recording rather than by undertaking a sample check.

Initial response

The CAA have agreed to review CAP 731 which details the UK requirements for maintenance of Flight data recorders in order to capture the appropriate error rate requirements of the complete recording.

This is a substantial technical document and will take some time to review and update in order to capture the requirements in recommendation 2022-015 and latest standards for digital as well as magnetic tape flight data recorders.

Update: August 2023

The CAA have reviewed CAP 731 which details the UK requirements for maintenance of Flight data recorders. An initial review of this document has taken place with a revision update inserted to capture the updated maintenance requirements of Magnetic Tape recorders to include the review of the complete recording. This document, which has not been reviewed for some time, requires further updates to capture the latest standards for digital Flight Data recorders. This further review combined with our current workload is expected to be completed by Quarter 4, 2023.

Update Due

23 October 2023

CAA Status

Open - Tracked actions

Recommendation text

The CAA and MAA jointly consider a coherent means by which non-recreational drone activity can be promulgated by drone operators and an associated method through which this information can be made available to other air users operating in either the UK Military Low Flying System or with a CAA permission to operate outside the provisions of ORS4 No.1496.

Recommendation Response

The CAA partially accept this recommendation. The CAA agree with the recommendation for the CAA and the MAA to work together toward enabling the safe integration of all airspace users and will be raised as a specific agenda item within the established working groups, including the Joint Air navigations Services Council (JANSC), to track and monitor progress. Noting that as UAS use proliferates this will necessitate ongoing consideration of how all airspace users operate, to ensure safe operations. UAS Visual Line of Sight (VLOS) operations, regardless of a commercial or non-commercial purpose, require the operator of the UAS to operate the Uncrewed Aircraft in a way which enables them to discharge collision avoidance responsibilities.

This should therefore not require routine pre-notification of flight. However, where the UAS is being operated in a nonroutine manner or in an area of greater risk pre-flight notification may be appropriate. If notification were a mandatory requirement, there are principally two available notification methods that can be considered for civilian UAS activity. Either utilising the NOTAM system or using an available UAS flight planning application. Noting NOTAMS are the standard form of notification in crewed aviation, the concept however of using NOTAM to notify routine UAS operations where crewed aircraft may be encountered below 500ft would quickly become impractical. When considering the UK Low flying system alone, figure 1 below highlights that most of the UK FIR is broken down into specified low flying areas and thus indicates crewed aircraft could be expected to operate below 500ft across most of the UK. The use of NOTAMS or other notification method to notify routine UAS operations would therefore likely not support crewed aviation flight planning due to volume of notifications generated. When considering the lead-in time for a NOTAM to be generated, released, received and interpreted by other airspace users, the use of NOTAM may not be suitable. This is particularly the case when considering the responsibilities of the UAS operator when operating routine VLOS in the first instance. Where ‘non-routine’ UAS flights are conducted, the use of a NOTAM is already considered, as either part of the UAS operators flight planning process or within the overarching approvals provided by the CAA.

This consideration is noted with CAP722 and may be specifically required as a condition of CAA approval for specific UAS operators. For instance, this can include requiring a NOTAM to be issued when approving VLOS operations above 400ft or considering the use of a NOTAM when operating near a Helicopter Landing site.

The use of the standard aviation notification method of NOTAM in this instance ensures widespread notification of the activity to all airspace users. Additionally, this mirrors the process followed by other airspace users who are undertaking ‘unusual aerial activity’, thereby ensuring commonality. When considering the use of available UAS flight planning applications, we would agree that there are several disconnected applications that are currently used by the industry. However, their use is not mandated. Their disconnected nature would make reliance on their use impractical for crewed aviation as this would not provide a common picture. When considering the concept of more broadly requiring pre-flight notification for routine UAS operations, this again may lead to issues regarding the accuracy and the timeliness of the information presented. As UAS numbers increase requiring greater integration, there remains a requirement to understand how all operations can be safely accommodated. We would therefore accept the underlying requirement of this recommendation that we continue to progress integration work in a coordinated manner with the MoD through the established joint regular working groups.

Update Due

31 March 2024

CAA Status

Open - Tracked actions

Recommendation text

It is recommended that the Civil Aviation Authority develops guidance in CAP1220, Operation of Aircraft Under E Conditions, regarding the use of existing guidance on the design and positioning of controls and displays used in the operation of the aircraft.

Recommendation Response

The CAA accepts this Safety Recommendation. We will enhance the existing guidance in Part B of the CAP1220 dossier as per the Safety Recommendation.We will aim to issue revised guidance within CAP1220 by the end of December 2023.

Update Due

December 2023

CAA Status

Open - Tracked Actions

Recommendation text

It is recommended that the Civil Aviation Authority clarify the scope of projects considered suitable to be carried out under CAP1220, Operation of Aircraft Under E Conditions, and introduce additional provisions, where necessary, to cater for the full range of project complexity envisaged.

Recommendation Response

The CAA accepts this Safety Recommendation. We will clarify the scope of projects within CAP1220 and also any additional provisions that might be required for more complex projects. This may mean limiting the complexity of projects within the boundaries of E Conditions and directing more complex projects to the usual certification routes in Part 21 and BCAR Section A. An element of this work will be to define what we mean by complex and non-complex projects. We will aim to issue revised guidance within CAP1220 by the end of December 2023.

Update Due

December 2023

CAA Status

Open - Tracked Actions

Recommendation text

It is recommended that the Civil Aviation Authority require an independent review of the Dossier for aircraft operating under the provisions of CAP1220, Operation of Aircraft Under E Conditions, to ensure the project meets the intent of the guidance and can be safely managed by a competent person.

Recommendation Response

The CAA accepts this Safety Recommendation. We will work to establish a process of independent review of the dossier required under CAP1220 to ensure the project meets the intent of the guidance and can be safely managed by the competent person. It is our intent to ensure the CAA is not the person that performs this review so as to maintain the overall current objective of delegation and proportionality of E Conditions in a deregulated environment. We will aim to issue revised guidance within CAP1220 by the end of December 2023.

Update Due

December 2023

CAA Status

Open - Tracked Actions

Recommendation text

It is recommended that the Civil Aviation Authority requires that the individual nominated as a competent person under CAP1220, Operation of Aircraft Under E Conditions, has the knowledge, skills, experience, and capacity to manage and oversee the experimental test programme registered on the Declaration.

Recommendation Response

The CAA accepts this Safety Recommendation. We shall review the current guidance in Chapter 6 of CAP1220 to determine any additional contents that may be necessary to fully assess all expected areas of competence as mentioned in the Safety Recommendation. We will aim to issue revised guidance within CAP1220 by the end of December 2023.

Update Due

December 2023

CAA Status

Open - Tracked Actions

Recommendation text

It is recommended that the Civil Aviation Authority enhance the guidance for the competent person and principal test pilot in the organisation, management, and conduct of the flight test programme, for an experimental aircraft project operating under CAP1220, Operation of Aircraft Under E Conditions.

Recommendation Response

The CAA accepts this Safety Recommendation. We will review and enhance the guidance for the competent person and principal test pilot as per the intent of the Safety Recommendation. We will aim to issue revised guidance within CAP1220 by the end of December 2023.

Update Due

December 2023

CAA Status

Open - Tracked Actions

Recommendation text

It is recommended that the Civil Aviation Authority promote the use of the recording facility on Garmin 1000 instrument systems and its potential benefits.

Recommendation Response

The CAA accepts this Safety Recommendation. The CAA will devise a safety promotion plan to promote the use of the recording facility on Garmin 1000 instrument systems and similar devices, highlighting their potential benefits to pilots and operators.

Update: August 2023

This is an update on the actions being taken by the CAA to address the safety recommendation above.

The CAA has devised a plan to promote the benefits of using the data recording facility on electronic flight instrument systems (EFIS). The CAA considers the primary audience for this promotion activity to be general aviation pilots who have these devices fitted as well as Approved Training Organisations (ATOs) and Declared Training Organisations (DTOs).

The CAA published an update to Safety Sense Leaflet (SSL) 05: Flight Under VFR in October 2022, highlighting how pilots can make use of EFIS data recording for post-flight analysis, self-assessment and self-improvement. The CAA is also identifying other appropriate publications (e.g. SSLs, Skyway Code, etc.) where this recommendation can be included. Additionally, the CAA is preparing a SkyWise to draw attention to this topic, which will be sent directly to the relevant training organisations.

Update Due

31 December 2023

CAA Status

Open - Tracked Actions

Recommendation text

The CAA reviews whether the Centralised Aviation Data Service (CADS) procedures, (Ref: UK IAIP ENR 1.10) generate the publication of sufficiently detailed information about operations below 500ft to enable other airspace users to accurately determine where the activity is taking place.

Recommendation Response

The CAA partially accepts this recommendation, insofar as the identification of an opportunity to improve the situational awareness of Pipeline Survey Operators and other civilian airspace users who routinely operate below 500ft AGL/AMSL within the UK FIR. We acknowledge the findings of the board report, regarding the situational awareness of the pilots involved and their ability to carry out their responsibilities of collision avoidance. We agree that both pilots share an equal responsibility for collision avoidance, as set out in (UK) SERA.3205 Proximity.

The Centralised Aviation Data Service(CADS)is one of many UK planning tools that have been designed to mitigate mid-air collision (MAC) between civilian and military aircraft routinely operating below 2000ft AGL/AMSL1. Guidance on use is detailed within the UK IAIP ENR 1.10.  The MoD funds the operating costs and development of CADS.

Flight for civilian aircraft operating below 500ft is subject to paragraph (5) CAA General ExemptionORS4 no.1496 (28 June 2021)

CADS provides a detailed route summary to all users and can highlight any potential confliction that may exist, this is unlike the low-level Civil Aircraft Notification Procedures (CANP)2,or Pipeline Inspection Notification System (PINS)3which both produce a NOTAM aligned to Military Low Flying Areas. However, the potential confliction is only highlighted for routes that are input by other users. This route is not subject to a NOTAM therefore it is incumbent upon the pilot to acknowledge any possible confliction and plan accordingly. It is very much an ‘early Situational Awareness (SA)’ tool, providing a prompt for further action to ensure that pilots reduce the risk of MAC as far as is reasonably practicable. The CADS system is only available to trusted users due to security; National Police Air Service, Helicopter Medical Services, pipeline inspectors, National Grid and Network Rail are amongst flights that can utilise the system when routinely operating below 500ft AGL/AMSL. Before any flight, operators should input their route into CADS and should employ CADS on every sortie however, crews must ensure that effective lookout remains a fundamental discipline for avoiding MAC. Civilian operators that utilise CADS are primarily doing so to mitigate against MAC with military users and not against other civilian operators. We conclude that the use of CADS by pilots should be used as a mitigation of mid-air collision (MAC) risk, and that the CAA should highlight this option to commercial operators, where practicable, that conduct flight below 500ftAGL/AMSL. We believe that several options exist which may mitigate such incidents occurring in future.

Update Due

None

CAA Status

Closed

Recommendation text

It is recommended that the UK Civil Aviation Authority require ab initio pilots to undergo training in the management of partial power loss situations in single‑engine fixed-wing aeroplanes.

Recommendation Response

The CAA accepts this Safety Recommendation. The CAA will launch a project to understand the root causes of partial power loss mishandling in single-engine, fixed-wing aeroplanes. The CAA will be guided by the project findings to develop and implement proportionate solutions for ab initio pilot training in the management of partial power loss situations.

Update: August 2023

This is an update on the actions being taken by the CAA to address the three safety recommendations listed above.

The CAA will consider these safety recommendations within the General Aviation Pilot Licensing & Training Simplification project, which will involve subject matter experts from licensing, instructors, examiners, as well as external GA stakeholders.

Phase 1 of the project recently concluded and established the overall strategic direction of the endeavour.

Phase 2 is scheduled to begin this month and will explore amending the relevant pilot training syllabi to include managing partial power loss events. This has the potential to affect multiple ICAO and sub-ICAO initial pilot training courses including the National Private Pilot Licence (NPPL), Light Aircraft Pilot Licence (LAPL)/Private Pilot Licence (PPL) as well as the Commercial Pilot Licence (CPL), Multi-Pilot Licence (MPL) and Airline Transport Pilot Licence (ATPL) integrated courses.

For the revalidation of single-engine fixed-wing aeroplane class ratings there is a requirement to complete at least one hour of dual flight training. The purpose of the flight is to refresh the pilot’s understanding of threat and error management with special emphasis on decision-making as well as basic handling skills for normal and abnormal operations. CAA TrainingCom Autumn 2019 contained a suggested profile for refresher flights and included partial power loss exercises. The CAA will consider incorporating this in a new AMC applicable to the revalidation requirements.

Upon determining the appropriate changes to the relevant ab pilot training courses and rating revalidation training, the CAA will devise and promulgate guidance and safety promotion material for managing partial power loss situations.

Update due

31 December 2023

CAA Status

Open - Tracked Actions

Recommendation text

It is recommended that the UK Civil Aviation Authority provide detailed guidance on techniques for managing partial power loss situations and to promote their use by instructors and examiners when conducting training for a rating revalidation in single-engine fixed-wing aeroplanes.

Recommendation Response

The CAA accepts this Safety Recommendation. The CAA will develop detailed guidance and techniques for managing partial power loss situations in single-engine fixed-wing aeroplanes based on the solutions developed by the CAA project team. The CAA will promote their use by instructors and examiners when conducting training for a rating revalidation.

Update: August 2023

This is an update on the actions being taken by the CAA to address the three safety recommendations listed above.

The CAA will consider these safety recommendations within the General Aviation Pilot Licensing & Training Simplification project, which will involve subject matter experts from licensing, instructors, examiners, as well as external GA stakeholders.

Phase 1 of the project recently concluded and established the overall strategic direction of the endeavour.

Phase 2 is scheduled to begin this month and will explore amending the relevant pilot training syllabi to include managing partial power loss events. This has the potential to affect multiple ICAO and sub-ICAO initial pilot training courses including the National Private Pilot Licence (NPPL), Light Aircraft Pilot Licence (LAPL)/Private Pilot Licence (PPL) as well as the Commercial Pilot Licence (CPL), Multi-Pilot Licence (MPL) and Airline Transport Pilot Licence (ATPL) integrated courses.

For the revalidation of single-engine fixed-wing aeroplane class ratings there is a requirement to complete at least one hour of dual flight training. The purpose of the flight is to refresh the pilot’s understanding of threat and error management with special emphasis on decision-making as well as basic handling skills for normal and abnormal operations. CAA TrainingCom Autumn 2019 contained a suggested profile for refresher flights and included partial power loss exercises. The CAA will consider incorporating this in a new AMC applicable to the revalidation requirements.

Upon determining the appropriate changes to the relevant ab pilot training courses and rating revalidation training, the CAA will devise and promulgate guidance and safety promotion material for managing partial power loss situations.

Update Due

31 December 2023

CAA Status

Open - Tracked Actions

Recommendation text

It is recommended that the UK Civil Aviation Authority updates its General Aviation safety promotions to include information for pilots regarding techniques for managing partial power loss situations in single-engine fixed‑wing aeroplanes.

Recommendation Response

The CAA accepts this Safety Recommendation. The CAA will devise and promulgate safety promotion material for managing partial power loss situations, which will be informed by the findings of the aforementioned CAA project.

Update: August 2023

This is an update on the actions being taken by the CAA to address the three safety recommendations listed above.

The CAA will consider these safety recommendations within the General Aviation Pilot Licensing & Training Simplification project, which will involve subject matter experts from licensing, instructors, examiners, as well as external GA stakeholders.

Phase 1 of the project recently concluded and established the overall strategic direction of the endeavour.

Phase 2 is scheduled to begin this month and will explore amending the relevant pilot training syllabi to include managing partial power loss events. This has the potential to affect multiple ICAO and sub-ICAO initial pilot training courses including the National Private Pilot Licence (NPPL), Light Aircraft Pilot Licence (LAPL)/Private Pilot Licence (PPL) as well as the Commercial Pilot Licence (CPL), Multi-Pilot Licence (MPL) and Airline Transport Pilot Licence (ATPL) integrated courses.

For the revalidation of single-engine fixed-wing aeroplane class ratings there is a requirement to complete at least one hour of dual flight training. The purpose of the flight is to refresh the pilot’s understanding of threat and error management with special emphasis on decision-making as well as basic handling skills for normal and abnormal operations. CAA TrainingCom Autumn 2019 contained a suggested profile for refresher flights and included partial power loss exercises. The CAA will consider incorporating this in a new AMC applicable to the revalidation requirements.

Upon determining the appropriate changes to the relevant ab pilot training courses and rating revalidation training, the CAA will devise and promulgate guidance and safety promotion material for managing partial power loss situations.

Update Due

31 December 2023

CAA Status

Open - Tracked Actions

Recommendation text

The MAA and CAA review conflicting Rules of the Air regulations with respect to formations of aircraft; specifically, Avoidance of Collisions within MAA RA2307 paragraph 9 and (UK) SERA.3210 Right-of-way.

Recommendation Response

The CAA accepts this safety recommendation from the UK Airprox Board (UKAB), and we note the Board’s conclusion that “each pilot was expecting the other to give way because each was operating to a different, and incompatible, regulation.”

M1: Draft a paper for inclusion at the next MAA/CAA Joint Coordination meeting.
M2: Hold a meeting with MAA specialists, outside of the Joint Coordination meeting, to discuss a way forward.
M3: Consider whether GM should be developed to advise pilots to consider that formations of aircraft may be less maneuverable than a single aircraft when applying right-of-way and determining how best to avert collision.

Update Due

28 February 2024

CAA Status

Open - Tracked Actions

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 January 2023

The requirement to gather flying hours data from both Open category and Specific category operations has been considered and the following position adopted:
Open Category:
The requirement for Open category UAS Operators to record flying hours as part of the annual Drone Model Aircraft Registration and Education Service (DMARES) will be encouraged, but not mandated; this would require regulatory change. DMARES is currently undergoing an extensive update programme, including moving to a new host platform, which is not expected to be complete until Q4/23 - Q1/24. Once successfully transitioned, the CAA Intelligence Team will be tasked to monitor failure rates based upon ‘hours flown’ and Mandatory Occurrence Reports (MORs).
Specific Category:
We will expand upon our privilege, under UK Reg (EU) 2019/947 UAS.SPEC.090, whereby any holder of an Operational Authorisation (OA) must make records available to the CAA upon request. As such, we will now start to collect 'hours flown' data for Specific category operations. New Acceptable Means of Compliance and Guidance Material is to be published in Q4/22 and includes a requirement for Specific category UAS Operators to establish and maintain a Flying Logbook and a separate Technical Logbook for each aircraft. Specific category UAS Operators already provide data to confirm that they have conducted a minimum of two flying hours in the last three months via their OA. This measure is an expansion upon that requirement and should enhance safety analysis, validate MOR data and assist a Market Surveillance Authority when compared against aircraft type, though some standardisation may be required.

Update Due

TBC

CAA Status

Adequate - Closed

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 areas have 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

Recommendation text

The intention of the alleviation is not to allow pilots who become visual with a landing site at a considerable distance to at that point descend below the height normally permitted.  Equally, on take-off aircraft are expected to climb directly to a height that complies with the minimum height regulations.

Therefore, consideration has been given to tying the alleviation to visibility, e.g., ‘at a distance not greater than minimum permitted visibility applicable to the flight’.

There  are  a  number  of  implications  to  this  proposal  relating  to  e.g.,  IFR  approaches  and  emergency service operations - police, HEMS, SAR. An alternative might be the inclusion of ‘in accordance with normal aviation practice’ which was used in some of the low-flying rules in the UK Rules of the Air Regulations prior to SERA.

Two working groups (London Helicopter Routes working group (CAA) and Helicopter Safety Review working  group  (CAA  and  Industry))  are  currently  looking  at  various  areas  of  VFR  helicopter  operations.  Included  in  these  is  a  review  of  the  current  VFR  minima;  they  are expected to report during summer 2022.

Any  of  the  foregoing  proposals  would  require  a  stakeholder  impact  assessment  and  consultation. In the event of a regulatory change being recommended this would have to be included in the parliamentary timetable. We will provide an update on progress in Q3 of 2022.

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: 10/02/2022

An internal working group consisting of Flight Operations policy specialists and helicopter Flight Operations Inspectors is planned to complete this review and confirm an action plan.

Update: 17/06/2022

The intention of the alleviation is not to allow pilots who become visual with a landing site at a considerable distance to at that point descend below the height normally permitted. Equally, on take-off aircraft are expected to climb directly to a height that complies with the minimum height regulations.

Therefore, consideration has been given to tying the alleviation to visibility, e.g., ‘at a distance not greater than minimum permitted visibility applicable to the flight’.

There are a number of implications to this proposal relating to e.g., IFR approaches and emergency service operations - police, HEMS, SAR. An alternative might be the inclusion of ‘in accordance with normal aviation practice’ which was used in some of the low-flying rules in the UK Rules of the Air Regulations prior to SERA.

Two working groups (London Helicopter Routes working group (CAA) and Helicopter Safety Review working group (CAA and Industry)) are currently looking at various areas of VFR helicopter operations. Included in these is a review of the current VFR minima; they are expected to report during summer 2022.

Any of the foregoing proposals would require a stakeholder impact assessment and consultation. In the event of a regulatory change being recommended this would have to be included in the parliamentary timetable. We will provide an update on progress in Q3 of 2022.

Update October 2022

The intention of the alleviation is not to allow pilots who become visual with a landing site at a considerable distance to at that point descend below the height normally permitted.  Equally, on take-off aircraft are expected to climb directly to a height that complies with the minimum height regulations.

The  review  of  the  SERA  regulations  continues  within  the  working  groups  and  changes  are expected; the ‘except for take-off and landing’ statement is embedded within the regulation and at this stage there is no final recommendation. The lack of coherent layout of the overall regulatory  requirements  causes  some  interpretational  difficulties,  and  a  key  area  being addressed is wholesale simplification of this part of SERA. The final outcome of this review is then  likely  to  take  considerable  time  for  regulation  change  due  to  the  legal  process requirements,  though  the  CAA  will  take  a  view  on  publicising  the  intent  of  any  regulatory proposal in advance once we get to that stage.

Update August 2023

An amendment to the applicable UK SERA section remains under consideration, but the current timelines associated with such a change is significant. This has resulted in a preference for a publication describing the ‘CAA Interpretation’ of the Part SERA requirements pertinent to take off and landing phases. The CAA intends to publish guidance on its interpretation of ‘except for take-off and landing’ in Q2 2023. This will aid the helicopter industry with a better understanding of its compliance with SERA 5005, until such time as any change to regulation is considered necessary.

Update November 2023

The current exemption in SERA must cover a wide number of different approach and departure scenarios and so there is no "one size fits all". In consultation with the CAA RW Section and other SMEs , the CAA Guidance and Interpretation for Helicopter "Take off and Landing" is as follows:

Helicopter ‘Take off and Landing’ -  The CAA interprets this to mean the final stages of an approach of the initial stages of a departure, whereby the aircraft is in a stable flight configuration at or below 500’agl and the area surrounding the FATO is clearly visible.

This text, together with applicability, has been placed on the CAA SAFER webpage; a CAP is being produced which when published will close this action item.

CAA Status

Open - Tracked Actions

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: 10/02/2022

Following consultation with industry, and internal discussions, we now have a better understanding of where the impediments to wider PinS adoption are. Meetings are planned in February 2022 between Flight Operations and Airspace Regulators to determine mechanisms to identify procedures that might be fast tracked due to minimal air space change requirements.

Update: 17/06/2022

The framework that will safely facilitate the use of Point-in-Space (PinS) operations continues to be developed. Flight Operations requirements and processes are already largely in place, the main focus remains on safeguarding the approaches and where the source data will be maintained. It is expected that by Q3 2022 procedures for hosting the procedures (expected to be in the AIP) and various charting requirements will have been confirmed. A parallel workstream producing guidance for PinS procedure implementation, and CAA website implications, is also planned to report by Q3 2022 enabling us to provide an update before the end of 2022.

Update: August 2023

A joint DfT/CAA invitation was sent out in the autumn of 2022 for eligible parties to register their interest for joining the third phase of GNSS implementation in the UK. This initiative to expand the number of GNSS instrument flight procedures is supported by DfT funding up to 75% of the project costs. This was circulated to 52 small airfields and a decision was made to extend the programme to include helicopter landing sites for Air Ambulance emergency services and consequently, the UK HEMS operators were contacted.

The result is that a mixture of fixed wing and rotary sites had been chosen by December 2022, and the rotary sites include current helicopter landing sites and hospital sites. An application is ongoing for PinS approaches to two sites Penzance and Tresco. A new CAP - Guidance for the implementation of Point-In-Space Helicopter Operations in the UK is currently nearing or at the final draft stage. An extract below: “The CAA considers that due to the nature of PinS and their safety implications, the implementation of such procedures in the UK should be scaled. Consequently, only applications to licensed aerodromes are considered to date with the exception for “Blue Light” services operating to/from unlicensed landing sites. Following the Post Implementation Review process, the CAA will consider expanding PinS applications to all types of operations serving all categories of landing sites.”

Note that the DfT have asked that the names of the sites are not released yet, and the date of CAP publication not set.

Update Due

25 July 2024

CAA Status

Open - Tracked Actions

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:10/02/2022

This is tied in with the working group evaluating SR 2021-032, and expected to deliver internal recommendations on revised guidance material.

Update:17/06/2022

Following a review by the FOI (RW) team it is clear there already exists significant research material, associated papers and guidance documents relating to this subject, most of which remain relevant and valuable. However, the existence of this material may not be as widely known as it could be.

Therefore, a SkyWise notification will soon be issued detailing the available information and guidance and the reason for the reminder.

Flight Operations have separately advised AMs and safety managers by mail of the SkyWise and its content; it will be recommended that they include the subject on the agenda of their next safety meeting. FOIs and IOs on both the AOC and FCL & ATO oversight teams will raise the topic as a discussion point at the next audit or inspection.

This topic has also been raised with the Onshore Safety Leadership Group as safety discussion topic for this year.

Update Due

N/A

CAA Status

Closed

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: 10/02/2022

The CAA is currently working on both a short-and longer-term solution of addressing the risks associated with distraction and undue customer pressure to crew.

Whilst there is no regulatory requirement for the tasking process to separate the flight crew from the customer, Operator’s SMS should recognise this and as such should have mitigations in place to address it. The CAA will review the affected operators` management system and ensure that it is included where relevant and then appropriately mitigated.

This item has been raised with the relevant industry groups and the CAA will continue to promote awareness through these forums.

Update: 17/06/2022

Whilst this incident involved a helicopter and the recommendation made specific reference to the interaction between the customer and the flight crew, the CAA will be issuing a Safety Notice to address this and other scenarios and types of operations where commercial pressure may be present in Q3 of 2022.

Update: October 2022

Whilst this incident involved a helicopter, the CAA issued a Safety Notice on the 18thJuly 2022 (SN2022/015 Commercial, Organisational and Client Pressure in Flight Operations) to address commercial pressure in general as well as made specific reference to the interaction between the customer and the flight crew which can have a detrimental impact on key operational decisions and potentially lower safety margins.

Update: August 2023

The CAA published Safety Notice SN-2022/005, Commercial, Organisations and Client Pressure in Flight Operations, on 18 July 2022, with the purpose of highlighting the risks associated with commercial pressure and the importance of separating the customer from the flight crew when making operational decisions. Verifying and monitoring the implementation of this Safety Notice has been incorporated into routine oversight activity, and the prevalence of commercial pressure has been considered when assessing operators’ safety management systems. Where identified as a hazard, commercial pressure can be highlighted at entity level and/or sector level, resulting in further engagement/promotion at the various industry forums attended by the CAA.

Update Due

25 July 2024

CAA Status

Open - Tracked Actions

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: 10/02/2022

This item has been raised informally with industry, but more work is required to understand the potential benefits for small fleet sizes (typical with this sector) and the types of operation conducted. External subject matter experts are being considered to assist with this project.

Update: 17/06/2022

As you are aware, the Onshore Safety Review (CAP1864) did not generate any specific actions or recommendations regarding FDM, but is referenced in Chapter 13 AOC management and operations:

13.15 The balance to be struck is between keeping risks as low as reasonably practicable whilst remaining commercially viable and compliant. Nevertheless, how can the management team be certain that operations manual SOPs are being followed by flight crew particularly on single-pilot operations where decisions go unchallenged. There is no doubt that Flight Data Monitoring (FDM) as required by legislation for larger aeroplanes and offshore helicopters has had an impact in identifying operations outside the established limits. At present helicopter FDM is not mandated for onshore operations but should be considered.

One of the challenges in this sector is the small fleet sizes and difficulty in using FDM data most effectively (rather than be seen as ‘policing action’). Nonetheless several onshore operators have invested in FDM over the past few years with mixed feedback on safety utility. However, we have agreed with the Onshore Safety Leadership Group that this will be a safety focus item for a bespoke industry working group that the CAA will support. The terms of reference of this group are yet to be finalised but will include both FDM and VHM (Vibration Health Monitoring). We will be in a position to provide an update on progress by the end of 2022.

Update: August 2023

The CAA-facilitated RW Safety seminar in Nov 2022 raised the profile of FDM, its uses and potential limitations. Following this, the Onshore Safety Leadership Group (OnSLG) sponsored a questionnaire to obtain feedback on current use of FDM and perceived barriers for more effective and broader use. The current focus for the CAA and OnSLG is the open actions from CAP 1864 (Onshore Helicopter Review), which did not identify FDM as a workstream; the survey may impact future activities not initially identified within CAP 1864. Once the survey has been completed and analysed, a level of priority will be attached and included in the Onshore safety plan. We anticipate survey return by end Q1 2023.

Update Due

30 October 2023

CAA Status

Open - Tracked Actions

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

24 July 2024

CAA Status

Open - Tracked Actions

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: 31/01/2021

The CAA has continued to strengthen the UK State of Design capability recruiting Design Specialists who will be able to engage with other authorities and seek participation in the SAE International Seat Committee to the design of seats for commercial air transport aircraft and where appropriate to make recommendations to minimise the chance of portable electronic devices becoming crushed in mechanisms.

The evolution of seat design standards will only be effective when agreed on a global basis. The UK CAA will continue to work with other lead international regulatory authorities to review and support future amendments and updates to the Certification Specifications and /or recommended practices.

The CAA continue to monitor similar PED entrapment events through the requirements of CAA Regulation (EU) 376/2014(as retained and amended in UK domestic Law under the European Union withdrawal Act 2018) and through its engagement in the SAE committee. Currently the CAA do not envisage an immediate change to the Certification Specifications or Recommended Practices to aircraft seat design. We will continue to monitor progress and changes through the SAE working group

Update: August 2022

As previously stated, the CAA has strengthened the UK State of Design capability by recruiting design specialists who are collaborating with other authorities and participating in the SAE1 International Seat Committee which is engaged in the design of seats for commercial air transport aircraft, and where appropriate, are making recommendations to minimise the chance of portable electronic devices becoming crushed in mechanisms.

The SAE seat committee and other international regulators recognise the risks that Portable Electronic Devices (PED) entrapment present and these risks have been discussed. The SAE seat committee have developed the following guidance material after presentations were provided by EASA on serious incident G-ZBKF:
“Small objects brought by the passenger (i.e., cell phones, PC tablets, computers, wallets, chargers, cords, keys, etc.) shall not be able to migrate to a location in the seat or furnishing where the object may prevent the return of critical features to a TTL (Take off, Taxi, Landing) position or create a potential fire hazard due to being crushed.

Seat furnishings shall be designed so that small objects are easily retrievable if they migrate into the seat or furniture structure. This may be done by prevention (seals, brushes, or shrouds), or the object can fall into an accessible area for retrieval. For any area that allows items to fall to the floor under or around a Seat Furnishing, there must be adequate access (removal of panels by crew member, by extending features such as a leg rest, etc.) to allow the crew member to retrieve them.”

Currently this guidance material is located within SAE AS6960 - Performance Standard for Seat Furnishings in Transport Aircraft. The intention from the international regulatory community is for this material to be included within the minimum performance standards for seats, within either SAE ARP5526 or SAE AS8049, which may be referenced in a future revision of CS-ETSO2 (ETSO-C127).

The CAA continue to monitor PED entrapment events through the requirements of CAA Regulation UK Reg (EU) 376/2014 (as retained and amended in UK domestic Law under the European Union withdrawal Act 2018) and through its engagement in the SAE seat committee. The next steps for the SAE committee is to revise SAE ARP5526 or AS8049 after which the CAA would consider how to adopt the revised standards.

We will continue to monitor progress and changes through the SAE working group, with the next committee meeting taking place in March 2023. In addition, our design and certification specialists are raising the risks of PED entrapment with UK state of design organisations for their awareness and consideration during their certification projects. 

Update August 2023

The UK CAA design specialist has now started to attend SAE1 International Seat Committee meetings to raise and discuss the entrapment of Portable Electronic Devices (PED) and how this can be mitigated. The committee have agreed to review and discuss the minimum performance standards for seats, with the view to amending either SAE ARP5526 or SAE AS8049, which may be referenced in a future revision of CS-ETSO2 (ETSO-C127). The CAA will continue to monitor PED entrapment events through the requirements of CAA Regulation UK Reg (EU) 376/2014 (as retained and amended in UK domestic Law under the European Union withdrawal Act 2018) and through its engagement in the SAE seat committee.

Update Due

30 November 2023

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 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: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update: July 2022

The Remotely Piloted Aircraft System (RPAS) Cyber engagement procedure has been updated to include an initial audit meeting between the assigned Cyber Certification Specialist and the RPAS Lead Auditor. This is conducted before commencing an OSC assessment and is like that which the Cyber Team conducts with the Project Certification Manager prior to an Initial Airworthiness assessment. The purpose of this meeting is to evaluate:

1.The complexity of the application.
2.The level of cyber requirements for the application; based on the complexity and the type of operation.
3.The subsequent level of involvement of the CAA for the application.

Additionally, the RPAS Sector Team is conducting a targeted recruitment campaign where three positions have so far been filled introducing new skill sets such as Structures, Operations, and Dangerous Goods. Budgetary approval has also been given to recruit additional resource in the form of two Software, one Battery and one Rotary Wing specialists.

This SR will be satisfied through the introduction of the Specific Operational Risk Assessment (SORA) however, given the sizeable nature of this work-strand it is not expected to be complete until the first half of 2024. In the interim, the current regulatory framework, particularly Article 11 and Article 12 to ‘UK Regulation (EU) 2019/947’, coupled with the extant CAP 722A and the newly developed AMC and GM will partially address the intent of this SR.

Update January 2023

We have recently updated our risk assessment methodology in CAP 722A3 to include a ten step method designed to assist with the identification of functional hazards, failure modes and mitigation means. In the longer term, this SR will be satisfied through the introduction of the UK Specific Operational Risk Assessment (SORA). SORA, as developed by the Joint Authorities for Rulemaking on Unmanned Systems (JARUS), remains a developing piece of work where version 2.5 has recently been published for external consultation on the JARUS website. We have been engaged with JARUS throughout this process and are expecting to start a comprehensive review of this latest version which will kick off the development of the UK SORA. Whilst we believe this satisfies the intent of SR 2021-022, this work is not expected to be complete until Q1/2 of 2024 and consequently, if this SR is to remain open, an update will not be available until the UK SORA is in place.

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 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: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update: July 2022

CAP 722A currently describes the Command and Control (C2) performance reduction considerations necessary due to potential Radio Frequency interference and introduces the need to conduct a site survey to assess hazards associated with high-intensity radio transmissions. This guidance will be bolstered through the introduction of new GM where a detailed description of the C2architecture and operational link management system, including contingency measures against loss of C2 link, is required. This can be found under GM1UAS.SPEC.050(1)(c) of the new AMC & GM.

Update January 2023

As previously reported, CAP 722A4 describes the Command and Control (C2) performance reduction considerations necessary due to potential Radio Frequency interference and introduces the need to conduct a site survey to assess hazards associated with high-intensity radio transmissions. This guidance has now been enhanced through the introduction of GM1 UAS.SPEC.050(1)(c) whereby the UAS Operator should consider the integrity of the C2 link. This includes a detailed description of the C2 architecture and the operational link management system, including the provision of any contingency measures against loss of C2 link. We believe this satisfies the intent of SR 2021-003.

Update due

None

CAA status

Closed

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: 20/12/2021

If an Operator relies on a technical safety feature which requires RF triggering, following the incident that generated these recommendations, it is unlikely to be accepted. Only systems that fail safe or activate in the event of a loss of link would be considered as acceptable.
If a loss of RF link, or an inability to establish a link, would result in an unsafe condition, then a comprehensive approach to RF surveys would be required and would be assessed. The RPAS Sector Team are producing an appropriate policy. An initial internal action has been identified to liaise with a spectrum specialist in the CNS team at the CAA to understand what a good RF survey may look like.

The likelihood of this type of requirement appearing is considered very small given the lessons learned from the Alauda Airspeeder incident.

Update: July 2022

Regular engagement with the Communication, Navigation and Surveillance (CNS)Team has been established for when the use of sensors, such as Electronic Conspicuity and VHF-VHF communications, is identified. The CAA is also working with Ofcom to create an authorisation process for a spectrum to be used for RPAS operations as well as to create an authorisation process for the safe use of RF equipment, which will include technology, spectrum, and licensing options; this process will be subject to Public Consultation. Additionally, a workshop with Ofcom is to be set up which, coupled with the CNS engagement, will ensure spectrum interference issues are being addressed.

Update January 2023

In line with our previous update, we remain engaged with both the Communication, Navigation and Surveillance (CNS) Team and Ofcom. Currently, there is no legal requirement within the UK Regulation (EU) 2019/947 for UAS Operators to provide separate radio frequency reports to the CAA. However, guidance has been developed and is contained within CAP 722A5 and AMC1 UAS.SPEC.050(1)(g) advising UAS Operators to retain records in order to assist ongoing oversight by the CAA. We believe this meets the intent of SR 2021-004.

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, 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: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update: July 2022

New GM will include guidance for Unmanned Aircraft System (UAS)Operators to conduct a thorough examination of current and relevant mapping and planning tools. It will also contain guidance on Remote Pilot reaction time analysis and UAS trajectory calculations in the event of a critical system failure. Some of the text is still under development but will be found under GM1 UAS.SPEC.050(1)(h)of the new AMC & GM.

Update January 2023

Guidance for UAS Operators to conduct a thorough examination of current and relevant mapping and planning tools is now located in GM1 UAS.SPEC.050(1)(h), and is supported in CAP 722A6. It also contains guidance on Remote Pilot ‘reaction time analysis’ to help address potential latency issues that may affect the time taken to execute a command resulting in the Unmanned Aircraft inadvertently leaving the Operational Volume. We believe this meets the intent of SR 2021-005.

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 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: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update: July 2022

The CAA provides several UAS safety system examples within the extant CAP722A which have now been transferred into the new AMC and GM. Additionally, whilst it is not mandated to have an installed Unmanned Aircraft (UA) safety system, GM will also ensure UAS Operators give due consideration to any safety system that could substantially reduce risk to both the aircraft and the public. This can be found under GM1 UAS.SPEC.050(1)(h)of the new AMC and GM.

Update January 2023

UAS safety system examples can now be found under GM1 UAS.SPEC.050(1)(h). Whilst it is not mandated to have an installed safety system, the GM ensures UAS Operators give due consideration to any safety system that could substantially reduce risk to both the aircraft and the public. Additional guidance on the systems description is provided in CAP 722A7. We believe this meets the intent of SR 2021-006.

Update due

None

CAA status

Closed

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: 20/12/2021

Primary safety modes such as the use of lost link 'return to home' modes in system software are not yet subject to certification. Other systems such as ballistic recovery & parachute systems may adhere to standards such as ASTM F3322-18, but this is not mandatory and the number of available systems on the market that adhere to this is low.

The RPAS Sector Team have begun to request any evidence that any systems used on a UAS for safety purposes adhere to any standard and are building a library of relevant standards as cases begin to present them. This process is potentially complicated by the development of the Certified Category which may mandate standards for some systems, and the conflict between standards released by competing bodies such as EUROCAE, ASTM, ISO and BSI. Nevertheless, any standards that are produced and identified will be considered for inclusion in any guidance material.

• The RPAS Sector Team already consider the robustness of any safety mitigation measure, in terms of its performance and integrity. All mitigations provided by technical systems are assessed to check:
• Performance relative to claimed reductions in severity
• Position and relevance in any bow ties or fault tree diagrams
• Integrity of function and assurance that the mitigation will function as claimed at all times or with an appropriate MTBF
• Its overall position within the Safety Risk Assurance Process, to understand how the applicant has formally assured the above, as well as how they selected the system as an appropriate mitigation.

As the Specific Category works on a case-by-case basis, every safety system is assessed individually for the use case described by the UAS Operator. Rather than a minimum performance requirement, each mitigation is checked to see if it achieves the claimed level of performance, and whether it can function as a mitigation as described.

Update: July 2022

The CAA is closely following the development of Standards by the EURCAE, ASTM and RTCA though most are still under development. Once established and subsequently adopted by the UK, Standards will then be considered for inclusion into the GM.
The current assessment process for the Specific category includes the consideration of safety mitigations against each hazard as well as the robustness of the safety systems. Submissions are allocated to a Case Inspector, on a case-by-case basis, and are intended to match skill set and experience with the complexity of the application; however, it is acknowledged that this can be a subjective process.

As introduced at CAA Update to Recommendation 2021-002 above, when the SORA process is in place assessments will focus more on UAS reliability, durability, and other technical and operational factors. This will ensure minimum performance requirements are addressed in a quantified manner, including adherence to performance standards wherever possible.

Update January 2023

We continue to monitor Industry standards as they develop and, once established, will decide whether they are to be reviewed and, if considered appropriate, adopted by the UK. Whilst the current assessment process for the Specific category remains subjective the new AMC and GM and revised CAP 722A provide more robust guidance to applicants when they are considering suitable platforms for their intended operations. When complete, UK SORA will focus assessments more on the UASs durability as well as the appropriate technical and operational factors. This will ensure that minimum performance criteria are properly addressed and, where possible, minimum operating performance standards adhered to.

Given the extended timelines associated with this work, if one is required, it could be sometime before an update would be available. We believe this meets the intent of SR 2021-007 and SR 2021-014.

Update due

None

CAA status

Closed

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: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update: July 2022

To promote ‘good practice’ across all UAS Operators the intent is for a recommendation to be inserted within the new GM. This can be found under GM1 UAS.SPEC.050(1)(g)(iii).

Update: January 2023

Whilst there is no legal requirement to make use of a flight data recording system we have recommended, under GM1 UAS.SPEC.050(1)(g)(iii), that UAS Operators should consider the importance of such a system. This is intended to promote good practice across the regulated community highlighting the significant value it would provide in both occurrence investigation, and when attempting to demonstrate regulatory compliance as described in UK Regulation (EU) 2019/947 UAS.SPEC.090 Access. We believe this meets the intent of SR 2021-008.

Update due

None

CAA status

Closed

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: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update: July 2022

The CAA has taken opportunity to highlight this matter to applicants in the new AMC and GM. This can be found under GM1 UAS.SPEC.050(1)(g)(iii).

Update January 2023

As mentioned in ‘CAA Update to Recommendation 2021-008’ above, there is no legal requirement to enforce the use of flight data recording systems however, we have taken this opportunity to include direction under GM1 UAS.SPEC.050(1)(g)(iii) whereby UAS Operators should consider the benefits such a system could bring in monitoring the performance of high-voltage energy storage devices. It is worth noting that it is the equipment manufacturer who is responsible for specifying minimum requirements for the monitoring of UAS high-voltage stored energy devices, and the UAS Operator who is responsible for defining the necessary processes, that satisfy those minimum requirements, as part of their risk assessment. We believe this meets with the intent of SR 2021-009.

Update due

None

CAA status

Closed

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: 20/12/2021

A new series of publications to replace CAP722A is scheduled for publication in summer 2022. This will address all the above recommendations.

Update: July 2022

The CAA has taken opportunity to highlight this to applicants in the new AMC and GM. This can be found under GM1 UAS.SPEC.050(1)(a)(i). In addition, the OEM of high-voltage stored energy devices are already labelling their equipment and identifying potential hazards to the user.

Update January 2023

We have introduced new guidance under GM1 UAS.SPEC.050(1)(a)(i) to highlight this to applicants. It is also worth noting that equipment manufacturers of high-voltage stored energy devices are labelling their equipment and identifying potential hazards to the user. We believe this satisfies the intent of SR 2021-010.

Update due

None

CAA status

Closed

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

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: 20/12/2021

There is currently no standard of this type agreed upon and accepted by the CAA. While some generic standards that could be utilised have been generated, such as ASTM F2910-14 (Standard Specification for Design and Construction of a Small Unmanned Aircraft System), ASTM F3002-14a (Standard Specification for Design of the Command and Control System for Small Unmanned Aircraft System), and ASTM F2909-19 (Standard Specification for Continued Airworthiness of Lightweight Unmanned Aircraft Systems), the decision to accept these into UK use and relevant publications would need to be managed in concert with the CAA’s work on the development of the Certified Category.

In the Specific Category, procedures within the RPAS Sector Team have changed so that applicants are advised to demonstrate adherence to any relevant standards when able. No standards will be automatically accepted as proof of compliance with regulation, but conformance with any relevant standard shows a degree of safety assurance.

Update: July 2022

The CAA is closely following the development of Standards by the EURCAE, ASTM and RTCA though most are still under development. Once established and subsequently adopted by the UK, Standards will then be considered for inclusion into the GM.
The current assessment process for the Specific category includes the consideration of safety mitigations against each hazard as well as the robustness of the safety systems. Submissions are allocated to a Case Inspector, on a case-by-case basis, and are intended to match skill set and experience with the complexity of the application; however, it is acknowledged that this can be a subjective process.

As introduced at CAA Update to Recommendation 2021-002 above, when the SORA process is in place assessments will focus more on UAS reliability, durability, and other technical and operational factors. This will ensure minimum performance requirements are addressed in a quantified manner, including adherence to performance standards wherever possible.

Update January 2023

This SR is covered under CAA Update to Recommendation 2021-007 and 2021-014 above.

Update August 2023

We continue to monitor Industry standards as they develop and, once established, will decide whether they are to be reviewed and, if considered appropriate, adopted by the UK.

Whilst the current assessment process for the Specific category remains subjective the new AMC and GM and revised CAP 722A provide more robust guidance to applicants when they are considering suitable platforms for their intended operations. When complete, UK SORA will focus assessments more on the UASs durability as well as the appropriate technical and operational factors. This will ensure that minimum performance criteria are properly addressed and, where possible, minimum operating performance standards adhered to.

Given the extended timelines associated with this work, if one is required, it could be sometime before an update would be available. We believe this meets the intent of SR 2021-007 and SR 2021-014.

Update due

None

CAA status

Closed

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: 19/05/2022

The CAA's response to this AAIB recommendation is currently being managed through the application of an Operational Directive: SD–2020/001. In due course an amendment will be made to the ANO. This may form part of a wider review of the ANO and the future regulatory framework in the UK.

Update due

29 June 2024

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: 19/05/2022

The CAA's response to this AAIB recommendation is currently being managed through the application of an Operational Directive: SD–2020/001. In due course an amendment will be made to the ANO. This may form part of a wider review of the ANO and the future regulatory framework in the UK.

Update due

29 June 2024

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

29 June 2024

CAA status

Open

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: 02/03/2022

The CAA is actively engaged in addressing the risks associated with carbon monoxide (CO) in general aviation (GA) and has undertaken several initiatives in this regard.

A CAA webpage dedicated to CO in GA was launched in July 2021 and contains useful information for pilots, including how to reduce the risk of CO poisoning as well as the benefits of carrying an active CO detector. The webpage also includes details of the various CO-related activities the CAA has undertaken and is regularly updated to ensure the information is relevant and accurate.

In July 2021, the CAA launched a survey of GA pilots to understand the extent to which active CO detectors are already used within UK GA and how these devices perform in the rugged GA environment. The survey attracted 600 respondents and the findings are available on the CAA CO webpage as an infographic. 

In addition, the CAA launched a 12-month operational trial of active CO detectors in September 2021 to assess the safety and practical implications of carrying active CO detectors onboard GA aircraft. It is hoped that the trial will also yield useful data on the extent to which carbon monoxide affects UK GA. Registered participants are asked to complete monthly surveys capturing their experience of flying with an active CO detector.

A report summarising the first three months of the trial is now available for download via the CAA CO webpage, and a copy is attached for your ease of reference.

A further update will be provided once the 12-month trial concludes.

Update January 2023

The CAA continues to be active on the issue of carbon monoxide (CO) in general aviation (GA). Since the last update the CAA released a podcast in May 2022 that featured a segment on carbon monoxide and the 12-month study that was ongoing at the time. An animation has also been uploaded to the webpage that includes guidance for GA pilots on flying with an active CO detector. The CAA has several other initiatives planned to raise awareness around CO and promote effective prevention and detection, which will be rolled out in the coming months. The CAA has now concluded its 12-month study of low-cost, commercial off-the-shelf CO detectors with attention-getting capabilities. By asking participants to complete monthly surveys over the course of a full flying season the CAA has gained insight into how these devices perform in GA aircraft as well as a better understanding of the pilot experience flying with them. The study also produced valuable data on CO levels in a cross-section of the UK GA fleet. Four quarterly summary reports have been produced and are available for download via the CAA webpage. A final report summarising the findings of the full 12-month study has been prepared and will be published in May 2023. The CAA is currently reviewing the evidence gathered from the 12-month study along with the safety data. The outcome of this review will be presented to the Safety and Airspace Regulation Group Executive Committee on March 22nd 2023 followed by the CAA Board on April 5th 2023.

Update August 2023

The CAA has now completed its review of the safety data and evidence gathered from the 12-month study of low-cost, commercial off-the-shelf (COTS) carbon monoxide (CO) detectors with attention-getting capabilities. The results were presented internally to the CAA Executive Committee (ExCo), and the findings from the 12-month study will be published in May.

The CAA recognises that COTS active CO detectors have an important role to play in combatting CO in general aviation (GA) alongside other measures such as robust maintenance. The 12-month trial combined with anecdotal evidence suggests that COTS devices can function reasonably at typical recreational GA altitudes, making them a low-cost, practical protection measure.

The N264DB accident highlighted the risk CO poses to occupants of piston engine aircraft. Whilst this risk may be known and understood by most qualified pilots the same cannot be said for consumers and third parties generally. The CAA seeks to address this and will be working with the GA community over the coming months to do so. Additionally, the CAA will continue to raise awareness generally around CO with a focus on prevention and detection measures.

Update due

30 November 2023

CAA status

Open - Tracked Actions

Recommendation text

The CAA considers highlighting the utility of monitoring relevant air communication frequencies to all drone operators, either through training syllabi or other appropriate media.

Recommendation response

The CAA partially accepts this recommendation, insofar as the identification of an opportunity to improve the situational awareness of UAS Operators and Remote Pilots. However, a more appropriate method of achieving this has been identified.
The CAA acknowledges the findings of the UK airprox board report, in regard to the situational awareness of the pilots involved and their ability to carry out their responsibilities of collision avoidance. The CAA agrees that both pilots share an equal responsibility for collision avoidance, as set out in SERA and UK Regulation (EU) 2019/947.
The board concludes that the use of VHF communication by the remote pilot should be used as a mitigation of mid-air collision (MAC) risk, and that the CAA should highlight this option to remote pilots. Whilst the CAA acknowledges that additional measures could be put in place to improve the situational awareness of both pilots, this should not include the monitoring of VHF communications by the remote pilot, because:

• It is unlikely to resolve similar situations in future, because:
  
  • Many GA airspace users within uncontrolled airspace are unlikely to make use of VHF equipment to transmit position reports, when not required (i.e.outside CAS/ ATZ etc.), and;
  • 
    It is not reasonable to expect a recreational UAS operator to understand, radio telephony phraseology without training, which in this instance would be disproportionate (in the Open category of operation) and may in fact distract them from the operation of the UAS, and obscure the sound of any approaching aircraft, thereby reducing their situational awareness.
    Instead, the CAA believes that a number of alternative, and more pragmatic options, exist which may mitigate such incidents occurring in future.
• Visibility and promulgation of hazardous activities
  Currently, most UAS flight control software only displays airspace restrictions (e.g., FRZs and other restricted areas). As highlighted in this report, a number of other hazards exist (which are promulgated within the AIP) and are displayed on the GA equivalent of ‘online flight planning software’. The CAA will recommend to providers of such services to UAS Operators, that they incorporate other relevant hazards to UAS operators (such as microlight activity, glider sites, unlicensed airfields etc.) within their software.
• Training
  Although, within the Specific category of operation, much training exists around the identification of other airspace users and areas of increased air-risk, there is limited training within the Open category. This may be compounded by the high-profile implementation of aerodrome FRZs (around licenced/certified aerodromes), which may lead some UAS operators to believe that by avoiding FRZs only, they are avoiding all aerodromes – which is not the case. The CAA will review open category training material, AMC and guidance material, and website information to ensure this is captured.
• Electronic Conspicuity of aircraft
  As already discussed, there exists an equal, shared, responsibility for the avoidance of mid-air collisions between all airspace users. The CAA believes that the implementation of electronic conspicuity, on all aircraft, is one method of aiding such avoidance. The CAA is forming a collective view of the future of UTM technology, which may include the requirement for electronic conspicuity in order to fully integrate UAS and other airspace users. The CAA invites UKAB to consider submitting a recommendation to the Department for Transport, in regard to the UKAB view on the right electronic conspicuity strategy for the UK in order to assist MAC avoidance within class G airspace.

Update: August 2023

With the publication of the new AMC and GM both Measures have now been addressed.

M1: Recommend providers of flight control software for RPAS operators to incorporate other hazards relevant to RPAS Operations, such as microlight activity, glider sites, unlicensed airfields etc, and to ensure the data they provide is correct.
M2: Conduct a review of open category training material, AMC and guidance material, and website information to clarify aerodrome avoidance requirements, implementing amendments as required.

Update due

None

CAA status

Closed

Recommendation text

It is recommended that the Civil Aviation Authority review the Visual Line of Sight distance figures in CAP 722 and amend the guidance to make it clear that just being able to see an unmanned aircraft is not sufficient for Visual Line of Sight operations and that pilots need to be able to demonstrate that at the distance they are flying, they can manoeuvre it rapidly to avoid a collision and can also land the unmanned aircraft safely following a loss of position-holding without reference to video or telemetry.

Recommendation response

The CAA accepts this recommendation. We have reviewed the content contained within CAP 722 and will amend the text accordingly. The draft wording is included below for information. This new wording will, initially, be contained within the Acceptable Means of Compliance (AMC) and Guidance Material (GM) to UK Regulation (EU) 2019/947 (the UAS Implementing Regulation) and is contained within the AMC/GM to the definition of VLOS, and the AMC/GM to the responsibilities of the Open Category remote pilot.

Due to the legal responsibilities that the CAA is subject to, in regard to the publication of Acceptable Means of Compliance and Guidance Material, under UK Regulation (EU) 2018/1139 (the Basic Regulation), this new draft text along with extensive other new guidance text is currently within the Rulemaking Process and will be published for consultation in June/July 2022 and adopted soon after. CAP 722 will then be withdrawn and re-published in a new format, in due course.

Update: August 2023

The CAA accepts the update to the recommendation. We have reviewed the content contained within CAP 722 and will amend the text accordingly to ensure that the requirement to manoeuvre the UA without the use of video or telemetry is emphasised.

This new wording will, initially, be held in our amendments log and will be implemented at the next revision cycle.

The draft wording is included below for information.

The proposed additional text is to be included in CAP 722 2.1.1 Notes.
“It is important to note that the sole use of video aids or telemetry to control the UA does not meet the requirements for VLOS.”

Update due

26 July 2024

CAA status

Open - Tracked Actions