What is the definition of an incident? Are all of them relevant to our use case / result in injuries?
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Firstly,
2FTS is a CAA authorised operator so we will follow what we are allowed to do in our Operations Manual.
As an aside, the CAA doesn’t mitigate the risk, the RPAS operator does. The CAA provides the legal framework through the ANO and largely CAP 722, amongst a few other documents. The operator takes these regulations and then either operates in the Open Category only, or forms a book on how they are going to apply this in their day-to-day operations, this manual is then presented to the CAA for approval. We have done the latter.
The FLYER ID, A2 CofC, and GVC are all qualifications that give you an understanding of the regulations and law, but is always incumbent upon the pilot/operator to manage the operational risk. An Operational Approval is required for the Specific Category or when you wish to differ from the normal operating regime. Essentially the Open Category is lower risk (Flyer ID only), apart from Open A2 which requires the A2 CofC and is essentially operating in built up areas (Medium Risk), the GVC is required in the specific category, which is higher risk. The operator measures the risk and decides what approval is needed.
To give you some idea of parity, the BMFA operates in the specific category, with an article 16 exemption.
The CAA gives us the ‘what’ and operators decide on the ‘how’. If all of our ‘how’ encompasses the regulation and law, then you get a CAA operational approval. This isn’t an operators ID which you can just pay for, but a reasoned and lengthy process that demonstrates an understanding of the regulatory framework and how we can use that to our advantage to get exemptions etc, from the norms. Which we have.
An example is that with a FLYER ID and OPERATOR ID you can only fly in the Open categories. Outside of built up areas and away from people. Our manual permits exemptions to this for A2 and Specific category operations in certain circumstances, where we follow our processes. To do so with your FLYER ID only as a normal operator would make the flight unlawful…this is an example of why this process has taken so long.
Most units are in built up areas, even a park in a built up area, isn’t suitable for Open Category operations. So we needed more than just operating with a FLYER ID and Operator ID to make this accessible to all.
I hope that gives you a better understanding of what we are trying to achieve and how complex that can be. We have our approval, we just need to put our internal training and assurance mechanisms in place and that takes time and as volunteers, like you, we are trying to make that go as quickly as possible.
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It predates me most of them. But several near misses where significant injuries were avoided by sheer luck. I don’t know of any actually significant injuries as a result of RPAS.
However, one I can remember, was when a cadet was struck by a drone on a DofE exped. Pilot had no quals or insurance. No injury but that was luck.
There was also a lack of clarity on what was legal and acceptable to the organisation. RPAS rules in the CAA world were constantly evolving and the internal documents did not reflect the law or appropriate procedures and processes.
This also resulted in some units operating as per the internal documents which unwittingly placed them outside the legislation. This was also compounded by the fact that nobody “owned” the internal policy.
In the past few weeks a unit has operated outside the regulation, albeit unwittingly and without any mal intent , but the CAA may not see it the same way when they view it on Facebook or Instagram.
This educate piece is something we hope to gap for everyone in the coming months.
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The granular data just isn’t there sadly.
The risk appetite is low, especially until we can share the entire process and operating manual with everyone. These are our real barriers and controls.
In the interim we have to limit or prohibit stuff. But as someone mentioned earlier in the thread. Our flying risk and the risk from 3rd party flying is different.
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If that is the case then you should not quote data like that. It’s potentially misleading and promotes a false picture of the actual risk; this risks driving even more risk aversion than we have now.
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The big unknown is the number of flights undertaken between the two dates, as drone use has risen markedly.
One ATC Squadron I know is next door to a major prison and given that drones are a common route to smuggle contraband into said establishment, should the Squadron stand down during the dark winter months when night arrives before 17:00
@Hercules, what happens if you cannot get the policy passed by OC 2/6FTS, potentially CFS, the new CRAFAC who is an unknown at this point and their risk appetite which maybe far less than the present CRAFAC, the OC 22 Group upwards. Is there a fallback position, or does the RAFAC continue to another lose a thing to attract cadets rather than other cadet forces who are doing flying and shooting etc.
Not all are relevant and the injury data isn’t there unless mentioned in the narrative. Similar to the CAA data it just isn’t granular enough, perhaps deliberately. That’s why we are asking for reports so we can build our own picture and adjust accordingly.
I realise that I’m not making a very good argument to support the case!!
But this interim measure is to ensure that the command appetite on risk in relation to this is known. The use of the word “should” is deliberate in the IBN as some have spotted.
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Not on the statistics bit, no. But the honesty and general openess here is genuinely really appreciated, even if I don’t agree with all the decision-making going on.
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Hi.
The policy is CAA driven, the risk is what the duty holder chain is willing to accept. That doesn’t include CRAFAC. I don’t think the change of post will change the appetite or the proposal for the rollout of this capability. That is already agreed and funded (externally).
The delay is now putting what has been planned into a delivery project and that is taking time as there are only 3 of us.
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The reality is that our operation will likely be unique and there is no data set that would reflect it accurately. Hence the need for us to build up our own picture and be cautious in the interim.
We needed to put our flag in the sand to give us a safe start point whilst also starting these conversations about risk involving drones and how this should be managed/perceived.
I haven’t even mentioned the reputational risk of any incident, which would be significant for the organisation and something that we are all conscious of when we are planning the measured return to outside flying.
So the DDH doesn’t like the policy or worse ‘gold plates’ it to make it more restrictive, what is the fallback position? At what level will the DDH reside at, will they ultimately be an aviator?
To be fair, that question isn’t really one for @Hercules . That’s a general issue we seem to suffer with the way the organisation is structured, having 6 RCs as the DDHs.
In theory they can carry on the ban, like SW are planning on doing with L144.
I will wait out on the final policy but I’m hoping great hasn’t become the enemy of the good.
In the short term all I want is to be able to use small (possibly kit built) model aircraft - no cameras or anything fancy to help cadets understand flight.
A2 CoC etc is all great but a nice to have not essential.
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Surely if we are using “should” to not be too restrictive it shouldn’t be partnered with the word “never”?
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Soo, from all the above, I don’t think we are worried at all about about injuries. Pounds to Pence the majority of drone ‘incidents’ are zone transgression, including prisons and airfields. What HQ are worried about is the reputational risk if one of the CAFVs flies in the wrong place. So once again, there is no trust in the volunteers to stay within the CAA rules.
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The DDH is an aviator as is the ODH. There are no plans to delegate this as the DDH has also to be the Accountable Manager (CAA) a singular person.
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Whilst this will be possible you will have to have an A2 or GVC with a fixed wing endorsement as the DMARES is aimed at multi rotor only. We will shortly be able to train both in-house.
The models will also be subject to the security restrictions. These apply to any RPAS and it’s often difficult to trace a source for some components, which means the kit can’t be cleared. We have already fallen foul of this with a drone kit. Not my rules, only the messenger on this one.
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That is certainly not what I said and harm prevention always comes first. But you’d be naive to think that reputational risk doesn’t come into our thoughts as well.
You can form your own opinions on why the rules are as they are, but having drafted them I can assure you that not trusting colleagues wasn’t in my mind when I did, nor is it now.
Enough from me for a bit. Let the project develop then pass judgement. I’m open to any feedback and will always answer emails or PMs.
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Our local town council employed a drone company to film remembrance parade last year, no way we would have stopped the parade to remove the cadets!
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Perhaps this is something that can be looked at once the main policy is out - perhaps a simpler system for the sub 250g category without a camera.
I would think the security considerations on these would be minimal too (no camera, analogue control signals, short range); I’m thinking of the type of thing you’d get from a toy shop.
I guess that’s what a lot of units would want to use anyway. We can’t all afford DJI etc.
I completely get why we’d want the higher end, qualifications based policies but at the same time we should be able to support the BMFA-type model aircraft projects and simple indoor flying.
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