The CAA published on 4 August an updated version of CAP722H Specific Category Operations: Pre-defined Risk Assessment Requirements, Guidance & Policy. The announcement is HERE.
We will exchange with the REG SIG on the detailed review of this release and share opinions. We had a preview of that release and our preliminary assessment is that on the face of it, there are no substantial changes, but…the direction of travel is clear. The separation distance from uninvolved people is not qualified as “horizontal”; that qualification applies only to flying close to assembly of people. However, the wording on “4.7 Separation from uninvolved people” and the M8 and M25 in our opinion clarify in the sense of a stricter interpretation of “if and how” the remote pilot may fly over uninvolved people.
Deliberately and consistently flying over uninvolved people with a 25kg drone is absolutely not in line with safety best practices! The challenge is that PDRA01, or rather its predecessor PfCO, was designed at a time when that 25kg threshold was appropriate. Now, with the new UAS on the market, that single threshold becomes a barrier, and we advocate for other PDRAs, or layers in this PDRA, that takes into account lower mass, speed, height, ie lower kinetic energy in case of impact, as risk mitigations to reduce separation from uninvolved people.
Also, the CAA’s announcement refers to the future application of the SORA methodology and their intention to assess PDRA01 and future PDRAs using this new methodology to ensure they remain safe and appropriate for future operations, and to make sure the operational conditions for PDRA01 are still appropriate for the evolving industry use cases.
We will have the opportunity to exchange with the CAA Team on the PDRA reviews in the context of SORA. Our priorities are: as mentioned above, scales of separation distances from uninvolved people based on kinetic energy; BVLOS with airspace observers; BVLOS in atypical air environment.
Any comments on this release of CAP722H, or on the PDRA(s) review, please use our “Feedback corner” on OSC and PDRA renewal in the “Final Words” and click HERE.
