Check the SLAs when making submissions to the CAA

We have recently renewed our Restricted NQE certification with the UK CAA, and in the first quarter of next year, the renewal of our PFCO is due.

We thought it might be worth a post the draw attention to the CAA’s quoted Service Level Agreements (SLAs) to process these applications and renewals.

 

It is worth noting that the CAA always deals in working days.

Permission for Commercial Operation (PFCO)

If you’re applying for a Standard Permission, then the CAA’s SLA is 28 working days (however you can submit up to 90 working days in advance).

If you’re applying for a Non-Standard Permission, i.e. you are submitting an Operating Safety Case (OSC) then there is no SLA; it is best endeavours and the CAA state that they will keep applicants appraised throughout the process.

National Qualified Entity (NQE and Restricted NQE)

The SLA for NQE applications and renewals (including Restricted NQE) is 90 working days.

On both the SRG1320 form that is used for PFCO applications and renewals, and the SRG1322 form that is used for NQE applications and renewals, there is a sentence that says: “Applications for renewal of permissions may be submitted up to 90 days prior to expiry  without loss of validity of the original date.”  On the SRG1322 (for NQE applications/renewals), this statement can cause confusion, as the SLA is 90 working days, so this sentence also means 90 working days.

There are a number of free online calculators you can use to easily work out how many days in advance you need to make your submissions; here’s one example (free-online-calculator) where you can enter your certificate date in the ‘starting date’ box, click the ‘-‘ button and enter ’28’ to count back 28 working days.

 

90 working days is actually almost 4 months in total time – a point worth noting when you are paying for the CAA’s service at the time your application/renewal is submitted.

NATS Visualisation Of Drone Flight At Airport Jul 2017

A useful reminder from NATS about the impact of illegal drone flying near to airports.

This is a visualisation of the impact to air-traffic of a drone incident from Jul 2017 at Gatwick airport.

Gatwick drone incident – 2 July from NATS on Vimeo.

Interesting visualisation, with a serious message about the impact of irresponsible Drone  operation.

Remember to fly safe and legal if you are operating Drones. Ignorance is not an excuse. Our advice is that if you are in any doubt – ask.

Drone, #FPV, #DronePilot, #CAA, #PFCO, #PFCO Application, #UAS, #RPAS

Making Changes To Your System May Change Your OSC

We are suggesting some basic considerations for those operators that are making changes to / modifying their PFCO specified drone aircraft systems.

No matter why you are changing the aircraft system or payload – you should always reconsider the validity of your Operating Safety Case or Operations Manual and your associated Permission For Commercial Operations (PFCO).

When you change the system, and importantly if you are adding a non aircraft OEM sub system; you should consider the implications of the change on a range of factors:

– Your original safety case presented to obtain your Permission For Commercial Operation (PFCO).
– Your aircraft system manufacturers warranty.
– Your insurance cover.
– Your current hazard assessments.
– The impact on the weight and balance of the aircraft.
– The impact on the aircraft system maintenance.
– The impact on the aircraft system reliability and life.
– The impact on operating procedures.
– The impact on human factors.
– The impact on crew training and experience.

Any modifications require some level of analysis and development of some supporting evidence to ensure that the Operating Safety Case (OSC) support the safety claims. Significant changes must be reported to the CAA to ensure that your PFCO remains valid or is amended.

We recommend:

– Assess the impacts of any change to an aircraft system even if you considered it to be safer.
– Gain experience of changes with planned training and trials flights.
– Prove the system in a controlled environment and to the limits of its intended operation.
– Generate evidence to underpin your safety claims.
– Document changed claims and evidence.
– Resubmit changes to CAA if significant.

Our Assistance:

We are assisting customers to analyse their system modifications and/or operational changes and successfully analysing and developing the additional OSC evidence for non standard systems and systems of systems, from different manufacturers.

If you are planning to make changes to your system, for example fitting modifications to increase performance or safety using a third party systems or spares then why not get in touch to get a point in the right direction.

Modification Example: 3rd Party Tether Sub System and Power Supply:

For example – are you considering adding a drone tether that is not provided by the aircraft OEM and is not on your current OSC ?

If you have already followed a logical approach to documenting the impact then that is great. If not, have you thought of the factors above? Has the modification affected your current Operating Safety Case (OSC), Permission For Commercial Operation (PFCO), Warranty or insurance ?

Modification Example: 3rd Party Aircraft Environmental Protection Measures:

For example – are you considering having a drone environmentally protected which is not provided by the aircraft OEM and is not on your current OSC ?

If you have already followed a logical approach to documenting the impact then that is great. If not, have you thought of the factors above? Has the modification affected your current Operating Safety Case (OSC), Permission For Commercial Operation (PFCO), Warranty or insurance ?

Our initial engagement is always free. We are always happy to help you should you require it. We could help you understand how a modification may affect your safety case and the list of implications and considerations listed above.

Use Live Chat or see other contact methods here.

 

#Drone, #FPV, #DronePilot, #CAA, #PFCO, #PFCO Application, #OSC, #Operating Safety Case, #Tether, #Drone Safety

A Visit By BBC Xray

A few weeks ago we had a fun packed visit from the BBC Xray team who were filming for their Photography Special.

We helped Omar Hamdi find out about all the dos and don’ts of flying a drone safely.  This included our experience session which saw him having his first few experience flights.

Here are a few screen captures from the BBC visit to out office and flying site.

See our very short debut on the following link (at 14:45 minutes in) while it is still view-able on BBC iPlayer. http://www.bbc.co.uk/programmes/b08y71x6

Whether you are a professional or hobby flyer you can book a professional and friendly drone support session. We cater for all levels of experience from zero to experienced.

Use our live chat facility on this site or contact us here.

 

 

#Drones, #FPV, #DronePilot, #CAA, #PFCO, #PFCO Application, 

Ignorance Is Not An Excuse – Check

We Assist Hobby And Commercial Drone Operators To Fly Safe And Legally.

A local group page on social media that we have on our feed recently added a post form a drone pilot, proud of their imagery captured of the USS George HW Bush.

When you see footage like this it makes you start to understand why the UK CAA, Department For Transport and EASA are proposing new measures to cover hobby and commercial drone operators.

There are many flying restrictions in this area of the UK and there is a No Fly Zone which is a Temporary Restriction on flying at this specific site. The restriction is from the surface to 2500 feet AMSL and valid until 17 Aug 17 @ 11:30. Police and Air Ambulance helicopters are exempt.

We regularly witness images and videos posted online from drone flights that make us wince.

This time it was not only us the flight also caught the eye of  a well respected drone news feed. Their article is linked below and our thoughts below that.

https://www.suasnews.com/2017/07/avoid-george-w-bush-solent-flight-restrictions/

Our thoughts –

If you’re flying a drone for either hobby or commercial use –  ignorance is not an excuse. Never assume you can fly – always check! Just because you see another drone flyer do it – it doesn’t mean it’s OK.

The onus is on the flyer to find out what the rules are for what they are flying, and where they are operating. With modern drones operating more sophisticated control systems and  their high definition payloads, the pilot needs to ensure they are flying safely and legally.  There are many facets to hobby and commercial drone operation such as safety, privacy and security.

The rules for safe flight of drones in UK have been available for many years, but you needed to work at finding them especially if you were not a commercial operator and so had not been made to learn about CAP 393 and CAP 722. More and more information is now being made available to drone flyers from many media sources including the myriad of social media platforms.

We use a number of these applications as well as UK CAA air navigation charts and NATS services.

As a result of the steadily growing number of reported incidents – in recent news, the UK Department For Transport (DfT) has published the findings of its public consultation on drones – https://www.gov.uk/government/news/drones-to-be-registered-and-users-to-sit-safety-tests-under-new-government-rules

 

Examples of content of the document:

“Owners of drones weighing 250 grams and over will in future have to register details of their drones to improve accountability and encourage owners to act responsibly.”

“In addition, a new drone safety awareness test means owners will have to prove that they understand UK safety, security and privacy regulations.”

These measures come after a consultation looking at ways to make drone use safer while maximising their potential.

There is also an EASA proposal published looking at a range of measures to ensure safe operation of drones more about that here – https://www.easa.europa.eu/easa-and-you/civil-drones-rpas

Our Support Is Available:

There is a range of free online assistance and a growing range of software applications to assist hobby and commercial pilots to fly legally. There is no excuse these days and if you are in any doubt – ask!

We love to talk drones – so you can contact us here or use our web-chat facility here IT’S FREE !!

 

Drone, #FPV, #DronePilot, #CAA, #PFCO, #PFCO Application, 

UK CAA – SRG1320 Application Issues

If You Are Applying For A UK CAA PFCO SeeBelow:

As a CAA UK Restricted Nation Qualified Entity (R-NQE) we receive information by email from the UK CAA regarding drone operation and the Permission For Commercial Operation (PFCO) applications process, to help the process move smoothly. Today received one such email. The email contained current issues that the CAA are experiencing with regards applications for PFCO.  Applications that have anomalies cost the CAA in resource time and may delay your application, while the operator ensures that issues are rectified. To assist operators about to apply for a PFCO, we have extracted the core content of the email to us:

“We are currently experiencing problems with applications regarding legal entity names not being identical on all aspects of the UAV applications received at the CAA. I have summarised the issues below:

1. The applicant must only fill out section 2 or section 2a of SRG1320. Section 2 if the applicant is a sole trader or partnership and Section 2a if a registered company (as referenced on the application form).

2. The Company or Sole trader name must be identical to the Insurance Cover. E.g. If ‘ABC Limited’ is on the application form, this needs to be the exact name on the Insurance Policy received.

3. Furthermore, the Limited Company name on the Application Form and the Insurance Policy, must match what is stated on Companies House. Additionally, a sole trader cannot trade as a Limited company. We will put the application on hold and ask for all three items to be identical.

We are receiving many Applications where the applicant has filled out the Sole trader section and the Limited Company section. Also, the applicant has different names on each part of the Application. E.g. ‘ABC Limited’ on the SRG1320, ‘DEG Ltd trading as ABC’ on Companies House, and just the pilot name on the insurance Policy.  

We have been instructed by the Authorities Legal and Financial departments to enhance this part of our assessment process for the issue of a permission/approval. Therefore, you may receive a few applications returned to you ‘on hold’, as well as applicants who have applied in their own right to the CAA.”

Our summary:

♦ Check that you complete the correct section of the SRG1320 for your specific organisation type.

♦ Ensure that the organisation name is accurately completed in all areas of your application – SRG1320 and the Insurance cover document.

♦ Ensure that if operating under a Limited Company that your company name used in Section 2a of the SRG1320 and Insurance documents accurately match the name on Companies House.

If you are not sure, then ask. Either through the CAA standard enquiries email uavenquiries@caa.co.uk  or, get in touch with us and we will point you in the right direction or the direction in which to find the answer.

#Drones, #FPV, #DronePilot, #CAA, #PFCO, #PFCO Application,  #SRG 1322, #SRG1322, Drone Pilot Assessment,

Drone Hobby Pilots – Our Advice

HOBBY FLYERS: NEVER ASSUME – ALWAYS CHECK!

Subjects Covered In This Post:

– The Legal Aspects
– Data Protection and CCTV Rules
– Harassment
– Insurance For Hobby Flyers
– First Person View Pilots
– Who Enforces The Law
– Choosing Hobby Flying Locations
– Complaints About Drone Nuisance – Including Towns and Cities
– IF IN DOUBT – ASK !

Legal Aspects

If you are flying a Drone for sporting and recreational purposes, including recreational (non-commercial) aerial photography and videography, they are considered to be model aircraft; the law makes no specific distinction on types of aircraft, other than weight limits, and all model aircraft pilots should read and understand the guidance contained in the CAA publications:

CAP 393 – Air Navigation: The Order and Regulations – CAA Link

CAP 658 – Model Aircraft: A Guide to Safe Flying – CAA Link

CAP 722 – Unmanned Aircraft System Operations in UK Airspace – Guidance – Auto stabilisation, flight automation and with video payloads. CAA Link

The latest version of these documents are available at the links above in electronic format and  www.caa.co.uk/publications is where you may also register for e-mail notification of amendments. Before flying a drone or any radio controlled aircraft, you should make sure you’ve read the latest legal requirements.

Rules Summary

These rules, applied with a little common sense, will ensure you are complying with the relevant legal requirements.

The basic aims of the main Air Navigation Order provisions is to prevent members of the public and full size aviation being endangered, and these provisions also help to limit the potential for causing nuisance and for invading privacy.

The basics are summarised in The CAA Drone Code:

♦ Always keep your drone in sight – This means you can see and avoid other things while flying

♦ Stay below 400ft – This reduces the likelihood of a conflict with manned aircraft

♦ Every time you fly, follow the manufacturer’s instructions – Keep your drone and the people around you safe

♦ Keep the right distance from people and property – 50m from people and property, 150m from crowds & Built Up Areas. So, that is keeping 50m away from people and properties outside of villages, towns and cities and 150m away from villages, towns and cities, unless you have CAA permission.

♦ You are responsible for each flight – Failure to fly responsibly could result in criminal prosecution

♦ Stay well away from aircraft, airports and airfields – It is a criminal offence to endanger safety of an a/c: could = prison for 5 years

The latest copy of the Drone Code can be found  – here

Data Protection and CCTV Rules

You need to be aware that the collection of images of identifiable individuals, even inadvertently, when using a camera mounted on a drone will be subject to the Data Protection Act. This act contains requirements concerning the collection, storage and use of such images. Drone operators should ensure they are complying with any applicable requirements or exemptions. Further information about the Data Protection Act can be obtained from the Information Commissioners Office website: www.ico.org.uk.

If you are using a drone with a camera, there could be a privacy risk to other people. The ICO suggest following their tips here and summarised below to help ensure you respect people’s privacy when using your drone.

Tips on responsible use of drones:

– Let people know before you start recording.
– Consider your surroundings.
– Get to know your camera first.
– Plan your flight.
– Keep you and your drone in view.
– Think before sharing.
– Keep the images safe.

Harassment

Other laws that protect individuals from harassment may apply when using your drone. It is worth checking which laws you need to be aware of before you fly your drone to avoid any unexpected complaints or disputes.

Insurance For Hobby Flyers

Consider insurance; even as a hobby flyer as you may be liable for 3rd party damage and personal injury claims should you have an accident and damage is caused.

For information, this mandatory for flying at a model flying association club or commercial operation.

First Person View Pilots

N.B. The CAA issues an exemption to Article 94 (3) for First Person View (FPV) operation. See here for details.

Who Enforces The Law

In June 2016, a Memorandum of Understanding was signed between UK National Police Chiefs, UK CAA, Home Office and the Department for Transport ( Memorandum of Understanding) – the CAA provide the rules, and the Police will investigate and enforce them. The Police now have an aide memoire for drone incidents.

Choosing Hobby Flying Locations

If intending to fly on private land, then the permission of the landowner should be sought. If flying on public land, such as a park or open access site, then you must ensure that there are no bylaws in place specifically prohibiting or restricting model flying.

The other main consideration is the overall suitability of the location for the activity, and that all flying can take place in compliance with the primary “endangering” provisions of the ANO and also in accordance with the distances mandated.

There are a number of emerging software applications to assist with safe Drone flying. These will identify your location and provide you with an indication of the flight hazards including classification of airspace. With these you may also have a facility to indicate to other application users that you are flying in that specific location. Like all of these tools, you need to ensure that you keep them up to date with the latest information.

Hobby Drone pilots should consider the location surroundings – what happens if the drone has a fault and flies away – how far will it fly, what directions might it travel and what can it endanger? e.g. straight up into manned aircraft.

If you have insurance – where does that insurance allow you to fly?

Complaints About Drone Nuisance

If you have any concerns about drones being used in your area, either from a safety or privacy perspective, contact your local Police on 101.

As a general rule, unless the drone pilot has permission from the CAA, he or she should not be flying a camera equipped drone within 150m of a ‘congested area’ (e.g. town or city), or at a public event.

The definition of a congested area in relation to a city, town or settlement means: any area which is substantially used for residential, industrial, commercial or recreational purposes

When the pilot does have permission from the CAA, such flights are usually restricted to flight distances no closer than 50m from people, vehicles and structures that are not ‘under the control’ of the pilot.

These restrictions mean that the use of a drone in public places is limited, and often not suitable or legal unless the operator has received the appropriate permission from the CAA.  The enforcement strategy has recently changed to better reflect the balance of capabilities between the CAA and local Police services.

The Police often have greater resources, response times and powers of investigation than the CAA.  To support this, the CAA has now agreed with the Police, in a signed Memorandum of Understanding, that the Police will take the lead in dealing with drone misuse incidents, particularly at public events, that may contravene aviation safety legislation or other relevant criminal legislation.

The UK CAA information regarding the reporting of safety concerns. UK CAA Safety Concerns Reporting.

OUR ADVICE TO HOBBY FLYERS IS:

IF IN DOUBT – ASK !

Please do not assume that just because one pilot is doing it, that it is acceptable, safe and legal. There are many British Model Flying organisations and a growing number of UK CAA National Qualified Entities that would be able to provide you with the information you require.

At AJSSL, we are always happy to provide independent advice and guidance to recreational pilots to ensure that they enjoy their hobby whilst flying safely and legally. We have a web-chat facility that you are welcome to use for queries.

#Drones, #FPV, #DronePilot, #RCModels, #RCDrone, #TheDroneCode, 

 

UK CAA – updated charges for PFCO applications

We’ve been working with customers who are going through the procedure for gaining a licence to fly commercially from the UK CAA  – a Permission For Commercial Operation (PFCO) and thought a reminder about the April 2017 changes to the CAA fees.

If you’re in the process of applying, or thinking about applying to operate commercially, you may not be aware that the cost of the application rose on 1st April 2017.  Usually, these charges are outside of any course fees that you will pay for ground school and examination etc.

On the 1st April 2017, the UK CAA brought into effect their new charges for General Aviation.

The fee for an initial application for a sub 20kg UAS, for a standard PFCO permission is now £173.

Application Type

Initial Charge

Renewal Charge

SUA (20kg mass or less without fuel) – ‘Standard’ permission or exemption

(See Note 3)

£173

£130

SUA (20 kg mass or less without fuel) – ‘Non Standard’ permission or exemption

(See Note 4)

£1,211

£130

UAS >20kg to 150 kg (mass without fuel) – permission or exemption

£1,211

(See Note 5)

£346

UAS > 150 kg (mass without fuel) – permission or exemption

£1,211

(See Note 6)

£346

Special UAS projects

(See Note 8)

£1,211

(See Note 7)

N/A

Issue of a duplicate permission/exemption

£57

N/A

Notes referred to in the table above:

3. ‘Standard Permission’ means any simple approval to perform commercial operations in accordance with ANO 2016 article 94(5) and/or a permission to operate an SUA of 7kg or less within a congested area in accordance with ANO 2016 article 95(2)(a).

4. ‘Non Standard’ permission/exemption means any approval which involves the assessment of an Operating Safety Case.

5. Plus charges in excess of 7 work hours at £173 per hour up to a maximum of £10,000 per year or part of a year.

6. Plus charges in excess of 7 work hours at £173 per hour up to a maximum of £20,000 per year or part of a year.

7. Plus charges in excess of 7 work hours at £173 per hour up to a maximum of £100,000 per year or part of a year.

8. A Special UAS Project involves consideration by the CAA to develop the existing framework under which the current regulation of UAS is undertaken. Plus charges in excess of 7 hours would be charged at £173 per hour up to a maximum of £100,000 per year or part of the year in which the CAA investigations take place apply.

9. All excess hours would be invoiced monthly in arrears by the CAA to the applicant and payable on demand.

10. Renewal of a permission/exemption assumes that there are no changes involved. Renewals which involve changes in either documentation or operating requirements will be charged as Variations

11. Reinstigation of expired permissions will be charged at the full rate as if they were new permissions.

(Extract taken from the full document – “Official Record Series 5 CAA Scheme of Charges (General Aviation”), which can be found here)

DO NOT FORGET OTHER RECENT CHANGES TO THE PFCO PROCESS:

– CAA insurance period requirements when applying and renewing – See original blog post here.

– CAA SRG1320 form you must use latest issue of this form – Issue 7 – See original blog post here.

 

UK CAA Information Notice – IN-2017/018 – SUA – NQEs

National Qualified Entities have been sent a link by the UK CAA to Information Notice – IN-2017/018 – Small Unmanned Aircraft – National Qualified Entities – which has the following summary:

“The purpose of this Information Notice is to notify all persons who may be associated with National Qualified Entities (NQEs), or who may use their services, of the intended role and the scope of the privileges granted under the CAA approval. It will also provide additional guidance on the CAA’s expectations with respect to the assessment process and the standardisation considerations for all CAA approved NQEs.”

The link is here.

As the summary indicates this IN reiterates information within in CAP 722 and provides additional guidance on the CAAs expectation. It is worth reading by NQEs as a reminder and for information by those who are engaging NQEs for obtaining their Permission For Commercial  Operation (PFCO). The key headings are:

1 Introduction
2 Scope
3 The Role
4 The Scope of Privileges Under NQE Approval
5 Assessment Considerations and Standardisation Requirements
5.2 Theoretical Knowledge Material
5.3 Assessment Methods
5.4 Practical Flight Assessment
5.5 Operations Manual Assessment
6 CAP 722
7 Queries
8 Cancellation

Any queries there are contact details on the IN and feel free to contact us.

 

MoD Competition – Autonomous Last Mile ReSupply

Autonomy on the front line: supplying Armed Forces on the battlefield. 

We have just seen that the Defence Minister Harriett Baldwin challenges industry and academia to design autonomous systems that can resupply our front-line troops. Information on the .GOV website here.

Are you involved in this Defence Science and Technology Laboratory, Defence and Security Accelerator competition: autonomous last mile resupply?

 

Graphic From .gov website – Vignette 2: emergency battle replenishment

Graphic From .gov website – Vignette 1: Resupply at reach

 

 

 

 

 

 

 

This is a fantastic opportunity in an area and market that we are interested in. If you or your organisation is involved, we would be keen to discuss opportunities for us to provide our specialist support to developers or government teams involved in this competition. We feel that we have some valuable qualifications, skills and experiences that would provide a team with an operational and competitive advantage over competition. We are a small agile company with specialist Defence Procurement (DP), Integrated Logisitic Support (ILS) and Remotely Piloted Aircraft Systems (RPAS) experience.

Our Principal Consultant  Alan Stevens has completed 22 years military service, 15 years in UK Defence procurement (contracted to both Industry and Government Teams) during which time was involved in Land, Sea and Air capabilities within the field of Integrated Logistics. He has been involved in support to Industry teams on complex high value bids. More recently has been involved in commercially operating unmanned air systems  (8 years) under a UK CAA permission for commercial operation (PFCO) and providing consultancy support to a range of large and small organisations developing RPAS based capabilities. The company also holds a UK CAA Restricted – National Qualified Entity. (R-NQE) allowing it to assess RPAS pilots and make recommendations to the CAA.

More about our team can be found here and Alans associated curriculum vitae can be found here and his LinkedIn profile is here

Our Capabilities are summarised here.

A list of Defence Projects supported can be found  here

We are experienced providers of discrete technical support under strict non disclosure agreements. If you are involved and wish to discuss how we can support your bid please contact us