Accident Alauda AS MkII

2021-002: It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722, Unmanned Aircraft System Operations in UK Airspace – Guidance & Policy, to require detailed evaluation of any Unmanned Aircraft Systems that use onboard systems to mitigate risks with Risk Severity Classifications of ‘Major’, ‘Hazardous’ or ‘Catastrophic’

We have recently updated our risk assessment methodology in CAP 722A to include a ten step method designed to assist with the identification of functional hazards, failure modes and mitigation means. In the longer term, this Safety Recommendation will be satisfied through the introduction of the UK Specific Operational Risk Assessment (SORA). SORA, as developed by the Joint Authorities for Rulemaking on Unmanned Systems (JARUS), remains a developing piece of work where version 2.5 has recently been published for external consultation on the JARUS website. We have been engaged with JARUS throughout this process and are expecting to start a comprehensive review of this latest version which will kick off the development of the UK SORA. Whilst we believe this satisfies the intent of Safety Recommendation 2021-022, this work is not expected to be complete until Q1/2 of 2024 and consequently, if this Safety Recommendation is to remain open, an update will not be available until the UK SORA is in place.

Adequate - Closed

Closed

2021-003: It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722, Unmanned Aircraft System Operations in UK Airspace – Guidance & Policy, to provide guidance on the planning, completion and documenting of Radio Frequency surveys to reduce the risk of Radio Frequency interference or signal loss when operating Unmanned Aircraft Systems

As previously reported, CAP 722A describes the Command and Control (C2) performance reduction considerations necessary due to potential Radio Frequency interference and introduces the need to conduct a site survey to assess hazards associated with high-intensity radio transmissions. This guidance has now been enhanced through the introduction of GM1 UAS.SPEC.050(1)(c) whereby the UAS Operator should consider the integrity of the C2 link. This includes a detailed description of the C2 architecture and the operational link management system, including the provision of any contingency measures against loss of C2 link. We believe this satisfies the intent of SR 2021-003.

Adequate - Closed

Closed

2021-004: It is recommended that the Civil Aviation Authority require Unmanned Aircraft System operators, that use unmanned aircraft which rely on a radio link to operate safety systems, to provide Radio Frequency survey reports to the Civil Aviation Authority for review, to ensure they are suitable and sufficient.

In line with our previous update, we remain engaged with both the Communication, Navigation and Surveillance (CNS) Team and Ofcom. Currently, there is no legal requirement within the UK Regulation (EU) 2019/947 for UAS Operators to provide separate radio frequency reports to the CAA. However, guidance has been developed and is contained within CAP 722A5 and AMC1 UAS.SPEC.050(1)(g) advising UAS Operators to retain records in order to assist ongoing oversight by the CAA. We believe this meets the intent of SR 2021-004.

Not Adequate - Closed

Closed

2021-005: It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722, Unmanned Aircraft System Operations in UK Airspace – Guidance & Policy, with guidance on how to define an Unmanned Aircraft System’s operational and safety areas, using up-to-date maps, accurate trajectory analysis and human or automated safety system reaction times, to ensure a safe operation.

Guidance for UAS Operators to conduct a thorough examination of current and relevant mapping and planning tools is now located in GM1 UAS.SPEC.050(1)(h), and is supported in CAP 722A. It also contains guidance on Remote Pilot ‘reaction time analysis’ to help address potential latency issues that may affect the time taken to execute a command resulting in the Unmanned Aircraft inadvertently leaving the Operational Volume. We believe this meets the intent of Safety Recommendation 2021-005.

Adequate - Closed

Closed

2021-006: It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722, Unmanned Aircraft System Operations in UK Airspace –Guidance & Policy, to provide examples of Unmanned Aircraft System safety systems.

UAS safety system examples can now be found under GM1 UAS.SPEC.050(1)(h). Whilst it is not mandated to have an installed safety system, the Guidance Material (GM) ensures UAS Operators give due consideration to any safety system that could substantially reduce risk to both the aircraft and the public. Additional guidance on the systems description is provided in CAP 722A. We believe this meets the intent of Safety Recommendation 2021-006.

Adequate - Closed

Closed

2021-007: It is recommended that the Civil Aviation Authority introduce requirements to define a minimum standard for safety systems to be installed in Unmanned Aircraft Systems operating under an Operational Authorisation, to ensure adequate mitigation in the event of a malfunction.

We continue to monitor Industry standards as they develop and, once established, will decide whether they
are to be reviewed and, if considered appropriate, adopted by the UK.

Whilst the current assessment process for the Specific category remains subjective the new Acceptable
Means of Compliance and Guidance Material (AMC and GM) and revised CAP 722A provide more robust
guidance to applicants when they are considering suitable platforms for their intended operations. When
complete, UK Specific Operational Risk Assessment (SORA) will focus assessments more on the UASs
durability as well as the appropriate technical and operational factors. This will ensure that minimum
performance criteria are properly addressed and, where possible, minimum operating performance
standards adhered to.

Given the extended timelines associated with this work, if one is required, it could be sometime before an
update would be available. We believe this meets the intent of Safety Recommendation 2021-007 and
Safety Recommendation 2021-014.

Adequate - Closed

Closed

2021-008: It is recommended that the Civil Aviation Authority require Unmanned Aircraft System operations under an Operational Authorisation to be fitted with a data recording system which is capable of demonstrating: compliance with the Authorisation’s conditions, safe operation and the logging of any failures which may affect the safe operation of the Unmanned Aircraft System.

Whilst there is no legal requirement to make use of a flight data recording system we have recommended, under GM1 UAS.SPEC.050(1)(g)(iii), that UAS Operators should consider the importance of such a system. This is intended to promote good practice across the regulated community highlighting the significant value it would provide in both occurrence investigation, and when attempting to demonstrate regulatory compliance as described in UK Regulation (EU) 2019/947 UAS.SPEC.090 Access. We believe this meets the intent of Safety Recommendation 2021-008

Partially Adequate - Closed

Closed

2021-009: It is recommended that the Civil Aviation Authority specify the minimum requirements for the monitoring of Unmanned Aircraft System high-voltage stored energy devices, to ensure safety of operation

As mentioned in ‘CAA Update to Recommendation 2021-008’ above, there is no legal requirement to enforce the use of flight data recording systems however, we have taken this opportunity to include direction under GM1 UAS.SPEC.050(1)(g)(iii) whereby UAS Operators should consider the benefits such a system could bring in monitoring the performance of high-voltage energy storage devices. It is worth noting that it is the equipment manufacturer who is responsible for specifying minimum requirements for the monitoring of UAS high-voltage stored energy devices, and the UAS Operator who is responsible for defining the necessary processes, that satisfy those minimum requirements, as part of their risk assessment. We believe this meets with the intent of Safety Recommendation 2021-009.

Adequate - Closed

Closed

2021-010: It is recommended that the Civil Aviation Authority specify the minimum requirements for readily identifiable warnings and safety information on Unmanned Aircraft high-voltage stored energy devices to inform 3rd parties of the potential hazard.

We have introduced new guidance under GM1 UAS.SPEC.050(1)(a)(i) to highlight this to applicants. It is also worth noting that equipment manufacturers of high-voltage stored energy devices are labelling their equipment and identifying potential hazards to the user. We believe this satisfies the intent of Safety Recommendation 2021-010.

Adequate - Closed

Closed

2021-011: It is recommended that the Civil Aviation Authority ensure that operators of Unmanned Aircraft Systems have an effective Safety Management System in place prior to issuing an Operational Authorisation.

CAP 722 already covers elements of SMS that operators could use for best practice and to manage safety risks.

The regulation only states a requirement for an SMS for Light UAS Certificate (LUC) approval holders under Part C UAS.LUC.030 of the Implementing Regulations for UAS. Due to the very wide range of possible operations within the Specific category for which an operational authorisation is required, it would not be practicable, nor indeed proportionate, to require every UAS operator to have a safety management system in place.

The RPASST exercise a proportional, performance based approach to applications, and required that elements of an SMS such as functional reporting and investigation processes are included as the complexity of the RPAS and operation increase.

Partially Adequate - Closed

Closed

2021-012: It is recommended that the Civil Aviation Authority, before issuing an Operational Authorisation to operate an Unmanned Aircraft System they have not previously had experience with, carry out a physical examination of the Unmanned Aircraft System to ensure that it is designed and built to suitable standards, and observe a test flight to confirm operation in accordance with the Operating Safety Case

When considering larger, more bespoke RPAS types such as the subject of this accident, then this is the =approach that will be taken. However, in other cases, dependent on the type of operation that is being authorised, such an approach may prove to be impractical. Where any features of design and construction have been included as mitigations in any risk assessment, then it would be appropriate for a pre-flight physical examination and an observation of an initial test flight to be conducted (bearing in mind that any test flight also requires an Operational Authorisation to be issued).

The RPASST will apply Performance Based Oversight (PBO) principles in order to target resource to risk. When a new platform is used that is likely to attract a high risk score, it will be prioritised for both physical direct inspection from an airworthiness Inspector and a flight test depending on the likely requirements. Even with COTS systems, the RPASST will use PBO to assess dynamically whether applications need a demonstration or test flight to show the requisite safety levels. The RPASST also carry out sector-level reviews of risk metrics to help assess where PBO assets are best deployed.

Partially Adequate - Closed

Closed

2021-013: It is recommended that the Civil Aviation Authority update Civil Aviation Publication 722, Unmanned Aircraft System Operations in UK Airspace – Guidance & Policy, to include reference to the consequences of not complying with the conditions of an Operational Authorisation to operate an Unmanned Aircraft System.

The Air Navigation (Amendment) Order 2020 (SI 2020/1555) introduced a number of new articles into the Air Navigation Order 2016. These create criminal offences, if the requirements of the UAS regulations that became applicable on 31 December 2020 are not complied with, along with the associated penalties.

This amendment was explained in guidance for UAS users within CAP 2013 (published 17 December 2020) and has been included in amendment 2021/01 to CAP 722 Chapter 4, Section 4.1.3 (March 2021).

Adequate - Closed

Closed

2021-014: It is recommended that the Civil Aviation Authority adopt appropriate design, production, maintenance and reliability standards for all Unmanned Aircraft Systems with aircraft capable of imparting over 80 joules of energy.

We continue to monitor Industry standards as they develop and, once established, will decide whether they are to be reviewed and, if considered appropriate, adopted by the UK.

Whilst the current assessment process for the Specific category remains subjective the new Acceptable Means of Compliance and Guidance Material (AMC and GM) and revised CAP 722A provide more robust guidance to applicants when they are considering suitable platforms for their intended operations. When complete, UK SORA will focus assessments more on the UASs durability as well as the appropriate technical and operational factors. This will ensure that minimum performance criteria are properly addressed and, where possible, minimum operating performance standards adhered to.

Given the extended timelines associated with this work, if one is required, it could be sometime before an update would be available. We believe this meets the intent of Safety Recommendation 2021-007 and Safety Recommendation 2021-014.

Adequate - Closed

Closed