Pre Defined Risk Assessments (PDRA)

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.

Specific Operations Competency Requirements

The competency of flights in the Specific Category will be determined by the risk assessment or the STS. This could range from a level of competency as defined in the Open Categories (such as the S2 CofC) through the requirements of a Certified operation pilot. In the middle ground, the UK has also introduced the GVC (General VLOS Certificate).

GVC (General VLOS Certificate)

The GVC provides a Remote Pilot Competency Certificate which provides a single qualification that is suitable for most VLOS operations within the Specific category. Additional modules may be added, currently, there is one: GVC Module 1 – BVLOS of Remote Pilot but utilising Visual Observers (i.e. EVLOS). There are both theoretical and practical aspects and it is to be conducted with an RAE (previously an NQE). It is valid for 5 years. Operators wishing to obtain this must fulfill some pre-requisites:

• Some may be exempt from theory – these will be in CAP 722.

• Obtain Basic Remote Pilot Competency – i.e. completion of CAA’s DMARES online training

• Hold a Flyer ID

GVC Theory Test

It will consist of 40 Questions, Closed Book and Multiple Choice/Long Answer/Mixed questions. The duration of the exam will be determined by the RAE. The exam will specifically cover:

• Air law/responsibilities;

• UAS airspace operating principles;

• Airmanship and aviation safety

The GVC theoretical examination may also include the A2 CofC examination in one sitting, but the examination must be expanded to 60 questions.

GVC Practical Test

This requires a practical demonstration of the pilot ability to comply with Operations Manual and STS or PDRA (I’ll cover the PDRA separately in another post). The test will be conducted outdoors and the RAE define pass/fail criteria. The test will specifically cover:

• Pre-flight Actions

• In-Flight Procedures

• Post Flight Actions

For the GVC Module 1 this will additionally include:

• BVLOS Operations with Visual Mitigation – General

• Pre flight Actions

• In Flight Procedures (with Visual Observer)

• Post Flight Actions (without Visual Observer)

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.

Operator and Remote Pilot Responsibilities in the Specific Category

Operator Responsibiltiies

The Operator is responsible for establishing:

• operational procedures to ensure the safety of the operations

• procedures to ensure that security requirements are complied

• measures to protect against unlawful interference and unauthorised access

• comply with regulations on personal data and carry out data protection IA when required

• guidelines for RPs to minimise nuisances, including noise, to people and animals

• each individual aircraft shall be installed with at least one green flashing light (from 1 January 2022)

• Record Keeping (maintenance, staff, qualifications etc.)

The Operator must designate an RP for each operation and If autonomous flight is planned then they shall detail phases of operation and responsibilities. They are also responsible for ensuring efficient use of radio spectrum in order to avoid harmful interference. When designating an RP, they must ensure each RP:

• Competent (as dictated by OA or STS)

• Follows competency-based training and as required by OA or STS Declaration

• Is informed on operations manual if required by RA

• Obtain geo zone information

When involving other staff as part of the crew, they must ensure:

• Completed OJTI

• Is informed on operations manual if required by RA

• Obtain geo zone information

The operator must ensure operations are carried out and records kept i.a.w the OA or STS Declaration. They must also only use drones designed to minimise noise and other emissions, ensure failure will not lead UAS to flying outside the designated operational volume or cause a fatality and the MMI (Man Machine Interface) shall minimise pilot error and not cause unreasonable fatigue. Finally they must define maintenance instructions and employ adequately trained maintenance staff.

Remote Pilot Responsibilities

Not everything is on the Operator, the RP also has responsibilities to ensure the operation is safe. They must only operate when fit to do so, i.e. not under the influence of drugs or alcohol. They must hold appropriate competency as required by OA or STS Declaration. To ensure the flight complies with the operational volume requirements they must ensure they obtain geo zone information and ensure the environment is compatible with OA or STS Declaration. They must ensure the UAS is safe and check Remote ID is working. All relevant information about the operation should be made available to the ANSPs, Airspace Users and other Stakeholders as required by OA or geo zone requirements. During flight, they must avoid any risk of collision with other aircraft, objects etc, and remain clear of emergency response areas and of course, comply with the OA or STS Declaration, Geo zone limitations, and Operator procedures.

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.

Specific Operations

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.

Open vs Specific vs Certified

As I said previously, the rules that apply are determined by which category you fall into, so the aim of this post is to help work out which drones/operations fall into which.

Open Category

An off the shelf drone in an safe area may fall in the “Open” category

My current feeling is that this is the most well defined, documented and understood category. I also think this is where the majority of hobbyists and even some commercials (by today’s standards) will operate. Essentially if your drone and operation are compliant with the following then you fall into the Open Category:

• Drone design is Compliant with the Delegated Regulation, Privately Built, or Placed on Market < 1 July 2022

• < 25kg Maximum Take Off Mass

• Remain a safe distance from people and do not overfly assemblies

• VLOS (*caveat for follow-me or observer usage)

• < 120m / 400ft Height (**caveat for obstacles and Model Gliders)

• Not carrying dangerous goods or dropping materials

• No autonomous flight

To expand on some of the Caveats.:

* for certain aircraft and operations in the Open Category the regulations allow flight of up to 50m from the Remote Pilot in “Follow-Me” mode OR when having an Observer situated alongside the Remote Pilot you may delegate VLOS to the observer so you can focus on the camera view.

** for flights within 15m of an obstacle you may fly higher than 400ft if you have permission from the owner of the obstacle and remain within 15m of that obstacle. But my understanding is that VLOS must still be maintained.

That’s the Open Category, in a nutshell. There are a further three sub-categories but I’ll go into these separately as these determine the rules that apply to each specific flight.

Specific Category

A drone flight in a city centre may fall into the “Specific” category

For those operations that site outside of the Open Category but not complex enough to sit in the Certified Category will be classed as Specific. The measures required to ensure safe flight are determined by a risk assessment. These risk assessments may be specific to your operation OR they may be based on standard scenarios already risk assessed. If using your own risk assessment you’ll need an Operational Authorisation (OA) from the UK CAA (caveat for Model Aircraft Clubs and Associations)***. If using a standard scenario (that has already been risk assessed and publised by the commission) then you only need to submit evidence and a declaration of compliance to those rules to the UK CAA.****.

In addition to the Standard Scenarios, the UK CAA are also using the concept of PDRAs (Pre Defined Risk Assessments), these appear to have a similar aim of the standard scenarios, i.e. less paperwork to send to the regulator to review and approve but these will require an OA, rather than just a declaration. I’m not claiming here that a decleration will be “less work” than an OA because you will have to satisfy the CAA that your decleration meets the requirements.

Again, I won’t cover the standard scenarios or pre-defined risk assessment here but will cover in a later post.

To expand on some more Caveats.:

*** Model Aircraft Clubs can operate in the specific category with an Authorisation (as opposed to an OA) if they have their own framework in place for safe operations and they have submitted these to the UK CAA.

**** Another scheme exists in the new regulations called a LUC (Light UAS Operator Certificate). I’ve not read this in too much detail but my understanding is that LUC holders can essentially authorize there own flights, but the requirements to get this LUC are very comprehensive and require things like a safety management system, training, manuals, etc. so I can’t imagine too many operators holding this status.

Certified Category

A drone delivering cargo or transporting passengers could be in the “Certified” category

Certified operations present the highest risk and as such have the strictest rules associated with it. Operators require certification, pilots require licenses and aircraft must be certified as per the Delegated Regulation. If the operation sits in any of the following then it must meet the certified requirements:

• over assemblies of people

• transport of people

• carriage of dangerous goods, that may result in high risk for third parties in case of an accident.

• a risk assessment determines that safety can only be maintained if the operation is certified

I hope that’s useful. My next post will look at more detail on the Open Category.

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