This is a fairly short post just to introduce the concept of the PDRA. PDRAs are not stipulated in EU law like the other areas I’ve covered. PDRAs have been created by the UK CAA. They sit somewhere between a full Specific Operational Risk Assessment (SORA) required for an Operational Authorisation (OA) and a Declaration to a Standard Scenario (STS). Like an STS, they consist of pre-completed risk assessments, however, they have been done by the CAA rather than the EU. The UK CAA will allow you to apply for an OA with a lesser amount of documentation. The PDRAs will contain the risk mitigation measures that the CAA requires you to adhere to in order to minimize the risk. These will be published in CAP722. The first one (UKPDRA01) will align with the current PfCO permissions and requirements. EASA is also publishing PDRA’s, these are documented in the AMC to the IR.

I’ve been trying to understand why we have PDRAs vs STSs. I guess both have the benefit of reduced paperwork but I think the STSs are quite rigid, being set in law. STS also has a set scope that has been set out in law too (see previous posts on specific here). So I think the benefit of PDRAs really comes from giving the regulator much more flexibility to set their own boundaries.

Summary

Specific Operations are those that can’t comply with the measures set out in the Open Category, but the risk is not high enough to sit in the Certified Category. All flights must comply with the applicable “Standardised European Rules of the Air Regulation” 932/2012 however the CAA have clarified this will not apply to VLOS flights. All operators in the Specific Category must be registered. Risk mitigations measures required are determined by a risk assessment that can be either conducted for the specific operation and submitted to the CAA for an Operational Authorisation Or generically as part of the Standard Scenarios (STS) submitted to the CAA as an Operational Declaration. Operators must be 18 years or over.

Standard Scenarios for Operational Declarations

These are documented in the annex of the IR. At the time of writing, there were not yet published, but they are expected to be in relation to the following:

drone with maximum dimension up to 3 metres in VLOS over controlled ground area except over assemblies of people
drones with maximum dimension up to 1 metre in VLOS except over assemblies of people;
drones with maximum dimension up to 1 metre in BVLOS over sparsely populated areas;
drones with maximum dimension up to 3 metres in BVLOS over controlled ground area.
Operations performed below 120m from the surface in Uncontrolled Airspace or Controlled Airspace after coordination and authorisation i.a.w procedures for that area

When submitting a declaration against an STS to the CAA it shall contain:

Admin info on UAS operator
A statement that operation satisfied requirements or point 1 and STS
Commitment to comply with mitigation measures (including. Operation, design, competency)
Confirmation that insurance will be in place

Once the CAA respond confirming receipt and completeness then the operation can begin, an Operational Authorisation is not required.

Operational Authorisations

If the flight doesn’t fit an STS then an OA will be required. An operator seeking an OA will need to submit the following:

Operational Risk Assessment (as per article 11) - it should be noted that CAA are not accepting any SORA (specific operational risk assessments) until after 31st December 2020.
Registration number
Accountable manager
Mitigation measures to allow the authority to assess the efficacy
Confirmation that insurance will be in place

CAA will then issue the OA when happy all information is provided and that a procedure is in place for coordination with ANSP (if operation crosses within controlled airspace) and they can conclude from the information that:

Safety objectives take account of risks
Mitigation measures are adequate (ground and air)
The operator has stated compliance with any privacy, data protection, liability, insurance, security and environmental protection rules

OAs are non-transferable and validity is determined on the OA itself by the competent authority. An OA may be for a single or number of operations in a specified time or location or both.

Aircraft Classes

The next update to the DR is expected to include two new UAS Classes (C5 and C6). This are for flying under the STS’s to be published. However as the CAA are not currently planning on following these I will not say any more about them here.

Small Print: These posts are a summary only, include my personal interpretation and are not intended to be a replacement for reading the actual rules.