ARPAS-UK

Access the consultation HERE. Below is our draft response (will evolve until 6 Jan) which can support you in drafting your own response. UAS / Drone operators in the Specific Category (PDRA01, OSC/ORA holders): you MUST respond to the CAA Service Charges consultation by 6 Jan 2025.

Go to Section 3: Charging proposals by individual scheme

• Do you have any comments relating to proposed changes for the Remotely Piloted Aircraft Systems Scheme?

For your information, the table below summarizes our analyses of the proposed changes to the CAA Service Charges:

We profoundly disagree with the proposed changes to the Remotely Piloted Aircraft Systems (RPAS) Scheme. These proposals are disproportionate, unfair, and lack adequate justification.

Proposed 2025/26 CAA Service Charges: Disproportionate Increases

The proposed increases are excessive and do not align with the principles of fairness or proportionality:

• PDRA01 charges: from £234 to £500. Increase by 2.1x. PDRA01 has been in place for over 10 years (formerly PfCO). 95% of operators in the specific category are operating under PDRA01. With the introduction of the digitised DiSCO platform and a shift to declarative oversight with periodic audits (e.g., auditing ~20% of applications), labour costs should have decreased due to efficiency gains. Why, then, are PDRA01 charges doubling? What are the cost savings from digitisation if not reflected in charges?

• New PDRAs: from £234 to £2185. Increase by 9.3x.  “we will be exploring the delivery of additional PDRAs…. we will set an initial price point of £2185 for non declarative PDRAs”. PDRA-01 current charge is £234. Judging by the PDRA01 survey done in November 2024, it seems that the CAA is also considering transitioning all the way to SORA where the entry point is a SAIL I application at £2185 as well. This is not sustainable for small operators, forming the majority of the community. 
  
  The #1 target for new PDRAs will be to provide a simple regulatory scheme for most frequent user cases with lower risk-profiles, between the Open category and the Specific category, or In the lower part of the Specific Category. 
  
  What justifies such a level of charges? Are you implying that the entry point to the Specific category will shift to £2k+?
  
• OSC/ORA renewal charges, before SAIL is implemented – or after: from £625 to £4992. Increase by 8x. Yet the process itself remains unchanged. How is this increase justifiable or reasonable?

• RAE: Even RAEs level 1 initial charges  would increase by 43%, despite no substantive changes to the service provided. What justifies this rise?

• Transition from OSC/ORA to a SORA SAIL II: from £625 OSC renewal charge to £3994 SAIL II application. Increase by 6.4x  
  
• Worse, if SORA applications are indeed location-specific : “non technical SAIL II renewal” at £3995: the end of it. 
  
  The concept of location-specific vs annual renewals for OSC/ORA is in itself a profound setback that  could jeopardize the industry. Adding a £4k charge per flight/mission would effectively kill the market. The CAA may be thinking in terms of repeated routes, like in CAT, but that is not at all the pattern for data capture with drones.
  
• Excessive hourly rate at £312 

The current hourly rates are excessive, far exceeding the fully loaded cost of a drone operator’s accountable manager – and probably of your own team’s wages. 

How do you calculate those hourly rates? What is your proportion of overhead?

£312 per hour x 1800 hours a year = £561 600 per year

£468 per hour x 1800 hours a year = £842 400 per year

Operators also face a lack of transparency and visibility regarding the maximum hours billed, effectively giving the CAA a “blank check.”

Needless to say that the Price Increase Table (p. 44) indicating 5.9% overall increase for RPAS is extremely misleading. The reality, as detailed above, is that charges would be multiplied by several factors compared to last year.

The proposed 2025/26 CAA Service Charges will further push part of the community into hiding into non-compliance in the Open Category .

We’ve stated several times that the unintended consequence of complex regulation is that people eventually give up, they don’t try and understand, they eventually mind their own business in the Open Category, outside of direct CAA oversight, and where the risk of being caught by the police for illegal flying is minimal.

Increase in CAA Service Charges in that proportion will likely undermine safety and increase non-compliance.

The proposed charge increases will cripple an emerging sector and undermine its impact in terms of GDP growth.

If we consider the proposed Service Charges together with the transition to SORA:

• A complex methodology that even the CAA operational teams will likely struggle to embrace it, and no signs at this stage that the CAA intends to absorb the SORA methodology in its role of aviation authority and produce simplified effective schemes for end-users;
• Potential profound setback to location-specific, meaning mission specific, SORA applications (the administrative burden of it,, the delays with CAA teams overwhelmed by the multiplication effect on the number of applications, the catastrophic multiplier effect on the cost of compliance if location-based)
• Lack of preparation on the drone operators’ side, by lack of visibility on the transition period.

There is no doubt that the proposed charges represent a clear threat to the sector’s growth and possibly economic viability.

It also raises serious concerns on the cost of compliance for the next steps, flightworthiness, product assessment RAE-F, and beyond the first steps of UTM. Are the cost of a full-blown complex regulatory approach compatible with the size and resources of the UK CAA and the UK industry? Clearly, the financial aspect MUST be factored into the decision-making process on regulation.

Finally, it raises the question of the regulatory approach that the CAA wants to embrace: FAA style where the cost of a Part 107 (equivalent to PDRA01) is $150, and the innovation approach is overall pragmatic? Or a European style, cascading the full SORA methodology with all its complexity from the “regulators think tank”, JARUS, straight to the local survey/construction/mapping/filming companies?

As a User payer, we seek transparency on the activities and costs behind those CAA Service Charges increases

• Can you please provide details of the underlying activities and teams driving the RPAS budget? 
• Can you also provide details on the number of users, current and projected, supporting the individual charges?
• What are the revenues generated by DMARES? Are they factored into the budget and calculations, so that the RPAS sector is considered as a whole?
• What is the internal process for approving expenditures with such significant impacts on end-users? Why are end-users not consulted in due course? As expressed above, the financial aspect must be factored into the decision-making process on regulation.
  

You can also add a comment in Section 2: Overview of charging proposals. Do you have any comments relating to the proposals linked to changes in our regulatory perimeter?

“See in Section 3 our response relating to the proposed changes for the Remotely Piloted Aircraft Systems Scheme and the exorbitant charge increases.”