Flight worthiness, pilot competency and certification
Overview of drone categorisation of risk
There is a drive amongst the UK drone industry to open more use cases and deliver increased benefits to stakeholders and the public. Often this requires that drone operations are conducted Beyond Visual Line of Sight (BVLOS) of the drone operator, are closer to people, are covering larger distance by larger equipment, and/or carrying payload. Current use cases include:
• hub- and point-to-point parcel deliveries,
• drones supporting missing person searches by the emergency services,
• inspections of long routes of infrastructure such as roads and power lines, and
• delivering medical and other supplies to remote locations.
However, with these more complex operations comes greater risk.
The increasing level of risk associated with drone operations corresponds with three categories, which are defined in CAA CAP 722 and UK Regulation (EU) 2019/947. In simplistic terms, they can be defined as follows:
• Open Category operations are those that can be operated with the lowest risk to people and property. These are operations with drones that are typically small and lightweight, and they are flown within Visual Line of Sight (VLOS) of the operator below 400 feet/120m. Along with a few other exceptions, only single drone operations are permitted, and no material may be dropped during the flight.
• Specific Category operations are those that pose a greater risk than Open Category operations, or that are operated outside of the Open Category rules. For example, where drones are intended to be flown BVLOS, over people or crowds, or in controlled airspace. To fly a Specific Category operation, the drone operator must conduct a risk assessment of the proposed operation and obtain an Operational Authorisation (OA) from the Civil Aviation Authority (CAA).
• Certified Category operations are those that pose the highest risk to people and property. These are operations with drones that are typically large and complex, and they may be used for high-risk operations such as transporting people or dangerous goods. For a Certified Category operation, the drone operator must have a remote pilot’s licence and the drone must be certified by the CAA.
What is changing to help achieve Specific Category operational authorisations?
The CAA is establishing a Stakeholder Working Group (SWG) to facilitate industry engagement, consultation, and collaboration on its Digitising Specific Category Operations (DiSCO) project. The project aims to contribute to the scaling of BVLOS drone operations in the UK, through enhancing the OA process in the Specific Category. It comprises four key elements, including:
• Standardised risk assessment approach based on the industry recognised Specific Operations Risk Assessment (SORA)
• Expanded and enhanced remote pilot competency framework, influenced through the expected SORA robustness levels
• New flightworthiness scheme that allows operators to demonstrate the robustness of their drone through assessment by an external Recognised Assessment Entity (RAE)
• New online application tool for an improved OA application process, including the above three elements.
Through the working group activities, the CAA intends to collaborate with industry on the development of these four elements, delivering an improved OA assessment based on a consistent, understood and streamlined process for both the CAA and the wider industry. This in turn will be a driving factor towards improved OA applications and their processing for intended BVLOS and other operations assessed within the Specific Category, thereby enabling scaling within the industry.
It remains the CAA’s intention to assess future pre-defined risk assessments (PDRAs) using the SORA methodology for a more efficient declarative compliance with safety risk of certain use cases. It is worthy to note that the lowest SORA safety assurance and integrity level (SAIL) score operations require wholly or mainly declarative safety risk compliance. Applying for a SAIL I or II operation may therefore not result in significant additional workload beyond that required for a PDRA, which will allow more flexibility compared to the rigid constraints/limitations of PDRAs.
Without a PDRA for an intended higher SAIL score use case, there remains the need for the operator to provide a body of evidence and safety argument to meet safety objectives and requirements defined through the SORA methodology, rather than a “tick-box” exercise. For example, a safety argument (or safety portfolio along with the Ops Manual) will be required to define the body of quantitative and qualitative evidence aligned with assessed ground and air risk mitigations for normal, abnormal and emergency considerations associated with the use case. This would include a demonstration where flightworthiness conformity forms evidence to mitigate wider operational risk relating to the use case. Drones and/or equipment certified for airworthiness may also be used for Specific Category operations as a means of risk reduction, assuming all related compliances are integrated into the mitigating evidence that supports the SORA.
Where Flightworthiness sits within the approval of equipment
Certified Category drone operations are expected to present an equivalent risk to that of crewed aviation, and so are subjected to the same regulatory regime of aircraft and operator certification and remote pilot licensing. For now, regulations for airworthiness, operations and licensing will be used as the basis for regulating the Certified Category whilst UK regulations relating to the Certified Category are still being developed.
As per CAA CAP 722 and UK Regulation (EU) 2019/945, a drone used in the Specific Category shall feature the technical capabilities set out in the OA issued by the competent authority.
A Notified Body (defined in the UK as an Approved Body) in its official sense is for the Open Category operations. At a European level, Notified Bodies assess and verify conformity to Technical Specification for Interoperability. At its most basic level, interoperability is the ability of a system or a product to work with other systems or products without special effort on the part of the customer. For example, all domestic electrical products on sale in the United Kingdom, such as hairdryers and drills, have the same plug. Interoperability is made possible by the implementation of standards.
An Approved Body is accredited against ISO/IEC 17065:2012 and is an independent third party appointed by the Secretary of State, and which meet the criteria of competence, integrity and independence. Approved Bodies assess and verify conformity to national technical specification notices. They operate in tandem with designated bodies who assess and verify conformity with national technical rules.
Building on its existing recognition and experience in accreditation, Ebeni is creating a multidisciplinary Accredited Services unit. Currently, it is not possible for manufacturers to comply with product requirements within UK Regulation (EU) 2019/945, and so class marking guidance is not included in CAP 722 until further CAA and DfT review. Whilst Approved Bodies are yet to be established in the UK, Ebeni is looking at the feasibility of such approvals across the full spectrum of Open/Specific/Certified Categories. The intention is to ensure an appropriate and consistent conformity assessment associated with drone class identification and category marking, and expectations on equipment and component design and test evidence through the flightworthiness assessment. This exercise will be in alignment with CAA decisions on the Market Surveillance Authority and related Conformity Assessment Bodies (primarily for the lower risk Open Category operations). It will also be in alignment with DiSCO project for which Specific Category operations will need a full flightworthiness assessment by an approved CAA Recognised Assessment Entity for flightworthiness – e.g. those higher than a certain SORA SAIL, and/or where a manufacturer of certain drone equipment has already been assessed for a SAIL “Mark”.