Given it’s so rare, and thus unlikely, why is it even considered a risk that needs mitigating? How will people know (in this rare event) whether it is or is not actually a risk they need to try and manage…people are unlikely to know whether the operator is competent / insured and will thus assume that any overflight is approved iaw CAA guidelines.
I’ll caveat this with I actually don’t really care that much - I’m just interested in the thought processes in our organisation that lead to us trying to put mitigations in place for every little risk regardless of the actual likelihood.
I’m not sure when I’ll find the time to do that, which again doesn’t lead me to believe this has been written by anyone with a working knowledge of how we volunteer.
I admire your engagement, i really want this to work but it just isn’t well thought out or considered from an end user’s approach. It’s great for OC2FTS who won’t ever need to do this and can absolve themselve of blame if anything goes wrong but it isn’t practicable, which is what ALARP is supposed to be about.
This might - in part - be a communications or wording issue.
Seems to be 2 things here.
You have the risk, small but certainly real, that a person might make an unauthorised overflight of cadets or CFAV. The operator could be malicious or simply stupid, but the risk to us is still there. It’s right to highlight that risk and recommend actions on, including reporting.
The second is the guidelines or rules for us operating UAVs, and again if we shouldn’t be overflying then it’s fair enough to state that as part of our risk controls we won’t do that in our activities.
It reads to me if some of the questions here come from having points 1 & 2 in the same document, rather than putting unauthorised overflights by 3rd parties in a safety bulletin, it’s in the documents around our operating rules.
This has the added issue that those with no interest in drone activities might miss the safety guidance in point 1 above.
I don’t take it as a personal attack, if I did, I wouldn’t engage on here and happily sit in the ‘ivory tower’ watching from afar. I have a relatively thick skin and encourage appropriate challenge and testing of stuff I propose or manage.
I would wholeheartedly support anyone who does the latter in your scenario, with a drone ‘2 miles away’. But if it’s directly overhead then we need to do something.
Hi…nobody is suggesting you have to pull out of an event. However, we do have a legal duty to ensure our people are always safe, even if that risk is introduced by a 3rd party, this is nothing new.
This IBN covers a scenario this is unlikely, but does present a significant risk of harm, which is above the acceptable threshold for the owner. So dynamic mitigation may be required to ensure safety.
There is definitely no threat of court in my posts. I’m more carrot based than stick. But having been there supporting colleagues who have made similar risk based decisions, I understand that the way it’s viewed in a courtroom may be different from on the day. I personally ask myself how others may view my decisions, with that in mind, that’s what I was trying to imply above.
High severity. A competent operator would likely avoid this in any case. We can only manage the knowns. Hence we may need to take action to prevent harm. We may not, but that a decision only the onsite person can make. The IBN outlines the intent but allows the decision to be made by the onsite person.
Thanks and reading the IBN can I totally understand that. That is my mistake as, in drafting the IBN, we tried to get as much out there as possible.
The intent is exactly as you describe.
ACTO75 and the RPAS Operating Manual will be published soon. There will then be a need to capture the details of those who hold existing qualifications before a phased return to outdoor flying using our manual and the brand new system specifically for RPAS RAs and use.
There is more to come in the next few weeks but a couple of recent safety issues promoted it to go out this week.
The Commandant has a legal responsibility as the CAA Accountable Manager and won’t be able to absolve themselves of anything. That’s why their name is on these documents.
Please give us a chance to present the full package before passing judgement.
What you are getting at the moment is snippets as we work towards a final solution. We are getting there and I can assure you that the focus is to minimise the amount of admin and time taken to authorise and assure RPAS flying. However, we are a CAA authorised operator and we do need to record some stuff legally. This is unavoidable but we are making it as automated and painless as it can be. You have no visibility of this at the moment as we are still working on it.
I hope we can get this sorted in a few months but there will be lots of very different comms before then.
Sorry …but I’d replied too many times and was temporarily banned.
It’s simple. The known is the overflight. Keep our people safe. If you can’t do that, or don’t have the information to be able to do so. The recommended solution is remove the pers from that situation.
It’s no different for any other risk we may face when doing an activity.
Lots of info in this thread and more comms via other mediums to help with understanding why we need to things, not just this. Hopefully this will give the ‘flesh on the bone’ that is lacking in the IBN.
I actually did the first operating safety case for this system to be used by the U.K. agent. It’s extremely effective but not great if you want a wifi signal nearby.
So we assume that it is an incompetent / uninsured operator by default.
Not convinced it is. In other activities, we have people who are qualified and competent to understand hazards in the environment and make risk based decisions on evolving situations. In your case, people might be making decisions with little to no knowledge of the environment and hazards associated with it - unless we always assume the worst as you suggest above, which brings with it a wide variety of impractical reactions as alluded to elsewhere.
The majority will not be unconsciously competent when having to make these decisons.
I think most, if not all, would agree that, “I always ask myself what this will look like in court” is definitely not a threat, but sharing my thought process on how I manage risks.
If I had said “if you don’t do this we’ll watch you hang in court” then I’d agree…but that’s not what was written.
Something I also reiterate in my later post, which you’ve chosen not to quote in full…but that wouldn’t have supported your sensationalist post would it.
All RPAS reportable accidents and serious incidents are required to be reported to the AAIB, regardless of weight of the drone or if they are being used for commercial purposes. Between 2017 and 2022, there were 334 high severity occurrences involving RPAS reported to the CAA, an average of 56 per year
Against
Drone use in the UK is growing. Figures from the Civil Aviation Authority state that as of March 2023, there were ‘513,860 active registered drone flyers and operators’
So if every drone operator ONLY flew once a year, the risk of accidents is 0.001%. If every drone operator flies 100 times a year (more likely) then the risk is now 0.00001%
I wouldn’t even bother including it in a risk assessment.
And what category were most of those? How many were near-miss type events with other aircraft, something which is irrelevant to here. If the total high severity incidents were 334 in 6 years, the number of incidents leading to injury is surely to be less?
