CAA updates CAP 722D: UAS Ops in UK Airspace – Abbreviations and Master Glossary
This is the fourth edition of CAP 722D: UAS Operations in UK Airspace – Abbreviations and Master Glossary. It is a full document review and update.
Aim CAP 722D is the abbreviations list and glossary of terms and for all documents in the CAP 722 series and is the single source of reference. This document also contains additional abbreviations and terms that may be useful for the UAS Regulated Community. This document does not replace definitions and abbreviations contained in relevant UAS Regulations.
Content The terminology relating to UAS operations continues to evolve and therefore the abbreviations and glossary of terms sections are not exhaustive. Terms and definitions in this document are drawn from a combination of applicable UAS regulation, emerging ICAO definitions, EASA and other ‘common use’ terms which are considered to be acceptable alternatives. Where possible, a reference has been provided, in italics below the definition.
Live Fireside Chat 01 | UK PDRA-01 Standstill – WATCH AGAIN
CEO Anne-Lise Scaillierez and ARPAS-UK Director David Thurston hosted the first live-streamed Fireside Chat, discussing the CAA’s announcement to delay significant changes to the UK PDRA-01.
Live Chat was available during the stream to Subscribers of our YouTube Channel
If you would like to read ARPAS-UK’s official Statement on the CAA’s announcement regarding PDRA-01, please find it here.
ARPAS-UK Statement on UK PDRA-01: welcome standstill, as advocated
ARPAS UK welcomes the Civil Aviation Authority’s (CAA) announcement regarding the postponement of significant changes to UK PDRA-01. The decision to maintain the current iteration of PDRA-01 until 31 March 2026 demonstrates an understanding of the industry’s need for stability during the introduction of UK SORA (Specific Operations Risk Assessment).
DiSCO, the digital platform for PDRA01 applications, was a success, and the community recognises it. There is no value in another cycle of changing regulations and format with no benefit in terms of operating envelope, and following a new methodology that has not been tested yet with the OSC/ORA holders.
In December 2024, ARPAS UK highlighted concerns to the CAA regarding the transition to the SORA methodology and advocated for “no impact, no change” on existing PDRA-01 operations. We are pleased to see the CAA addressing these concerns and delaying immediate changes, allowing operators to continue their activities without disruption.
Learning from Europe’s Experience: very low adoption of very conservative PDRAs. Must put more thoughts into proportionate, useful PDRAs.
Feedback from the EASA IAM Forum in October 2024 highlights the low adoption rates of SORA-based PDRAs and Standard Scenarios in Europe. The EASA PDRAs derived from SORA are notably conservative and impose restrictions far greater than those under UK PDRA-01. They do not adequately meet industry needs and as a result adoption so far is low. The SORA methodology is developed, but its implementation is still a work in progress. It has become clear now that those initial scenarios need rework to become effective tools. A review of UK PDRA01 that would result in an alignment with one of those PDRAs would hinder “business as usual” operations for many UK operators.
Advocating proportionality in the UK approach to SORA
While aligning UK operations with the global standards followed by JARUS member countries offers long-term benefits, ARPAS-UK remains concerned about the challenges posed by the transition to SORA:
The SORA methodology should enable us to do more complex operations, more consistently, and following an approach that can be exported.
For lower risk operations however, a full SORA application is most likely disproportionate and … beyond many operators’ grasp. ARPAS-UK suggests adopting simpler, more relevant authorisation frameworks, such as additional PDRAs or generic SORAs, where the CAA has done the work of mastering the SORA methodology and provides proportionate standard recipes that operators can easily understand and implement.
The current PDRA-01 covers drones up to 25kg, yet many operators fly much smaller, lower-risk drones. ARPAS UK continues to advocate for additional PDRAs tailored to the realities of drone operations, focusing on:
Reduced distances from uninvolved people for low-mass, low-speed, low-height drone operations.
BVLOS (Beyond Visual Line of Sight) with visual observers, also known as extended VLOS.
Higher operational heights, exceeding the current maximum of 120m.
We propose standardised and scalable authorisations, not location-specific, and facilitated through a streamlined, digitised process. These improvements would make low-risk activities more accessible, encouraging more operators to apply for or renew their Operational Authorisations.
As the UK’s trade association for the drone industry, ARPAS UK strongly supports regulation that is both appropriate and proportionate. We believe that relevant and accessible authorisations will encourage operators to remain within the regulatory framework, promoting industry growth and maintaining high safety standards.
By continuing to engage with the CAA and advocating for sensible regulatory solutions, ARPAS-UK aims to ensure that the UK drone industry thrives under a system that balances safety with operational practicality.
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CAA Future of Flight – Industry Update Jan 2025
The UK Civil Aviation Authority (CAA) releases their latest CAA Future of Flight update this month, providing a PDRA-01 update and highlighting key milestones for 2024.
Topics include:
PDRA-01 Update
Completion of 11 Public Consultations
Future of Flight Stakeholder Working Groups
CAP 2973 Cyber Security Guidance for Innovators
PDRA-01 Online Application Tool Rolled Out for RPAS Users
CAP 2988 – Using MCN Networks in Aviation
Law Commission Regulatory Framework Consultation on Autonomy in Aviation
ACOMS Airspace Notification System Rolled Out for UAS Operators
Delivering Scalable UAS BVLOS in the Specific Category – CAA Delivery Model – CAP3038
Atypical Air Environment Policy-Concept Published
Looking Forward to 2025
DfT Launches a Call for Ideas on the UK Integrated National Transport Strategy
Read the full CAA’s Future of Flight update below.
Protected: Massive increase in CAA RPAS Service Charges: ARPAS-UK response to the consultation
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heliguy™ Granted Operational Authorisation for BVLOS Drone-in-a-Box Operations
ARPAS-UK member heliguy™ has been granted Operational Authorisation by the CAA (UK Civil Aviation Authority) to perform BVLOS (Beyond Visual Line of Sight) drone-in-a-box missions, in atypical air environments, using the DJI Dock ecosystem.
heliguy™ plans to use the authorisation as a framework for delivering automated and remote solutions for enterprise organisations. The approval enables the heliguy™ team to use both the DJI Dock 2 and the original DJI Dock, in non-segregated airspace.
Missions will be managed by their pilot team, either from the Remote Operations Control Centre (ROCC) at their headquarters or via the their Drone Command Unit.
This authorisation was awarded following successful BVLOS flights conducted at Komatsu’s Smart Construction facility in northern England.
Attention Drone Operators: CAA Service Charges to be Multiplied. Have Your Say by 6 Jan 2025!
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 Chargeswill 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 Chargesincreases
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.”
