CAP 722 Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy

Safety and Airspace Regulation Group
Unmanned Aircraft System Operations in UK

Airspace – Guidance & Policy
CAP 722
Published by the Civil Aviation Authority, 2019
Civil Aviation Authority

Aviation House
Gatwick Airport South
West Sussex
RH6 0YR
All rights reserved. Copies of this publication may be reproduced for personal use, or for use within a
company or organisation, but may not otherwise be reproduced for publication.
To use or reference CAA publications for any other purpose, for example within training material for
students, please contact the CAA at the address above for formal agreement.
Previously published as DAP Unmanned Aerial Vehicle Operations in UK Airspace – Guidance, June 2001
First edition of CAP 722, 29 May 2002

Second edition, 12 November 2004
Third edition, 28 April 2008
Third Edition incorporating amendment 2009/01, 14 April 2009
Fourth Edition, 6 April 2010
Fifth Edition, 10 August 2012
Sixth Edition, 31 March 2015
Seventh Edition, July 2019
Seventh Edition, amendment 2019/01, 23 July 2019
Seventh Edition, amendment 2019/02, 30 July 2019
Seventh Edition, amendment 2019/03, 4 September 2019
The latest version of this document is available in electronic format at www.caa.co.uk

CAP 722 Contents
Contents
Contents 3
Revision History 8
Foreword 12
Point of Contact 14
Abbreviations and Glossary of Terms 15
CHAPTER 1 | General 24
Introduction 25
1.1. Policy 25
1.2. Scope 25
Legal Considerations 26
2.1. The Chicago Convention 26
2.2. European Regulation 26
2.3. National Regulation 27
2.4. Exemptions and Permissions granted by the CAA 30
2.5. Insurance 31
2.6. Enforcement 32
2.7. Lead Agency 33
CHAPTER 2 | Authorisations and Approvals 34
UAS Classification System 35
1.1. Scope 35
1.2. UAS Classifications 35
1.3. Future Classification Development 36
Authorisation Requirements Map 37
2.1. Scope 37
2.2. Basic Requirements 37
Authorisation to Operate 40
3.1. Scope 40
3.2. Introduction 40
3.3. Operational Authorisations 40
3.4. Images and other Data Collection Requirements 45
3.5. Meaning of Commercial Operations 46
3.6. Operations 47
3.7. Insurance 53
3.8. UAS Operating Safety Case (OSC) 53
Application Process 55
National Qualified Entities 56
Regulatory Enforcement 57
6.1. Source Documents 57
Civil UAS Remote Pilot Competency 58
September 2019 Page 3

CAP 722 Contents
7.1. Scope 58
7.2. Policy 58
7.3. Maximum Operating Mass 58
7.4. UAS Flight Control Mode 59
7.5. Alternative Means of Compliance 60
7.6. Granting of a small unmanned aircraft permission or exemption – Critical elements
for remote pilot competency 62
7.7. NQE Recommendations 62
7.8. Other Factors 63
7.9. Flight Radio Telephony Operators’ Licence 63
CHAPTER 3 | Policy 64
CAA Policy on Detect and Avoid Capability 65
1.1. Scope 65
1.3. Aim 65
1.4. General 65
1.5. Separation Assurance and Collision Avoidance Elements 66
1.6. Minimum DAA Requirements for Routine Operations 67
1.7. Research and Development 68
1.8. Factors for Consideration When Developing a DAA Capability 68
CAA Policy on Human Factors in UAS Operations 70
2.1. Scope 70
2.3. General 70
2.4. Design Human Factors 71
2.5. Human Factors That Affect Design Teams 71
2.6. Design Induced Remote Pilot Human Factors 72
2.7. Design Induced Maintenance Human Factors 73
2.8. Outstanding Problem Reports 73
2.9. Production Human Factors 74
2.10. Operational Human Factors 74
2.11. Authority and Control 75
2.12. Ergonomics 76
2.13. Flight Crew Awareness 76
2.14. Transfer of Control between Remote Pilots 76
2.15. Crew Resource Management 77
2.16. Fatigue and Stress 77
2.17. Degradation and Failure 78
2.18. Maintenance Human Factors 78
2.19. Future Trends 79
CAA Policy on UAS Autonomy 80
3.1. Scope 80

CAP 722 Contents
3.3. What is the Difference between Automation and Authority? 81
3.4. Use of High Authority Automatic Systems 81
3.5. Delegation to a High Authority Automatic System 81
3.6. Potential Future Developments 82
3.7. General 82
3.8. Human Authority over Autonomous UAS 83
3.9. Safe Operation with Other Airspace Users 83
3.10. Compliance with Air Traffic Management Requirements 83
3.11. Emergencies 83
3.12. Factors for Consideration when Applying for Certification of Autonomous Systems
84
CAA Policy on Security Issues for UAS Operations 85
4.1. Scope 85
4.2. Policy 85
4.3. Factors for Consideration when Developing Security for UAS 85
4.4. Current UAS Security Work 87
CAA Policy on UAS Spectrum Issues 89
5.1. Scope 89
5.3. Aim 89
5.4. Policy 89
5.5. Radio Regulatory Framework 90
5.6. Spectrum Availability 90
5.7. Allocation of Spectrum 93
5.8. Use of 35 MHz, 2.4 GHz and 5.8GHz 93
CAA Policy on UAS Registration 94
6.1. Scope 94
6.2. Policy 94
CAA Policy on Radar Surveillance 96
7.1. Scope 96
7.2. Policy 96
CHAPTER 4 | Certification & Airworthiness 99
Certification 100
1.1. Scope 100
1.2. Lead Agency 100
1.3. Policy 100
1.4. Certification Objectives 101
1.5. Initial, Continuing and Continued Airworthiness 102
1.6. Initial Airworthiness Processes 102
1.7. Continuing airworthiness processes 103

CAP 722 Contents
1.8. Continued airworthiness processes 104

General Certification Requirements 105
2.1. Scope 105
2.2. Policy 105
2.3. Applicability 105
2.4. Certification Process 105
2.5. Certification Basis 107
2.6. Interrelationship between the Three Stages of Airworthiness Oversight 107
What Level of Certification Do I Need? 110
3.1. Scope 110
3.2. Policy 110
3.3. Aircraft Classification 110
General Safety Assessment Points 112
4.1. Scope 112
4.2. Policy 112
4.3. Assessment Steps 112
4.4. Safety Assessment Considerations 113
4.5. Other Considerations 114
CHAPTER 5 | Operations 115
Airspace Principles 116
1.2. Scope 116
1.3. Policy 116
1.4. Airspace Principles for UAS Operations in the UK 117
1.5. General Principles for UAS Operations within Segregated Airspace 118
1.6. General Principles for UAS Operations in Non-Segregated Airspace 118
1.7. Detect and Avoid 119
1.8. Temporary Danger Areas 120
1.9. UAS Operating in Controlled Airspace and Flight Restriction Zones 122
Cross Border Operations 127
2.1. Scope 127
2.2. Policy 127
ATM Procedures 128
3.1. Scope 128
3.2. Policy 128
Emergency ATM Procedures 130
4.1. Scope 130
4.2. Policy 130
Aerodrome Operating Procedures 132
5.1. Scope 132

CAP 722 Contents
5.2. Policy 132

Incident and Accident Procedures 133
6.1. Scope 133
6.2. Definitions 133
6.3. Policy 134
6.5. Points of Contact 136

CAP 722 Revision History
Revision History
Seventh Edition September 2019

A number of small amendments have been made to CAP 722 Seventh edition since it was
published in July. The most recent changes are underlined in red. In the interests of clarity,
a separate document has been published to highlight all these small amendments:
CAP722 publication amendment record
Seventh Edition July 2019

This amendment updates references and text in accordance with ANO 2016 and its
subsequent amendments, changes to European regulations brought about by the
publication of the New Basic Regulation in Autumn 2018, incorporates Guidance material
that has been published in the interim, and brings terms, definitions and
procedures/processes up to date as they have evolved, and a change to the structure of
the document.
In addition, the opportunity has been taken to transfer the Appendices into two separate,
but related, documents with CAP 722A covering the development of Operating Safety
Cases, and CAP 722B covering the requirements for National Qualified Entities.
Some minor editorial amendments have been made to this edition, since original
publication in July. A list of these changes can be found on the CAP 722 publication web
page.
Sixth Edition March 2015

CAP 722 has been completely refreshed and restructured under this revision. Key
changes to the document are:
 Complete restructure of the document.
 Updates to all Chapters (including Abbreviations and Glossary of Terms).
 Introduction of a Concept of Operations Approach (ConOps)
 Introduction of the UAS OSC - Unmanned Aircraft System Operating Safety Case
(formerly titled Congested Areas Operating Safety Case).
 Introduction of an Approval Requirements Map.
 Removal of Military Operations Chapters.

 Addition of Alternative Means of Compliance to demonstrate Operator Competency.

 Introduction of Restricted Category Qualified Entities.
Fifth Edition 10 August 2012

The changes at this edition primarily concentrate on updating areas where terms,
definitions or procedures have evolved significantly and where details of chapter sponsors
have also been changed. The specific areas to note are:
 Revised Abbreviations and Glossary (also reflected throughout the document),

which reflect worldwide developments in UAS terminology.
 Introduction of a Human Factors chapter.
 A complete rewrite of the ‘Civil Operations, Approval to Operate’ chapter.
 Amendments to civilian Incident/Accident Procedures.
 A complete revision to Section 4 (Military Operations), which reflects the formation

of the Military Aviation Authority (MAA) and the revised Military Aviation Regulatory
Publications.
Fourth Edition 6 April 2010

This edition incorporates the changes to legislation introduced in Air Navigation Order
2009 (ANO 2009) regarding the requirement for operators of small unmanned aircraft to
obtain a CAA permission when their aircraft are being used for aerial work, and also in
some cases for surveillance or data acquisition purposes (now termed small unmanned
surveillance aircraft).
Unmanned aircraft having a mass of less than 7 kg are now covered by this new
legislation, which is intended to ensure public safety by applying appropriate operational
constraints, dependent on the flying operation being conducted and the potential risks to
third parties. In line with this change, some guidance on the additional details to be
provided within an application for permission to operate small unmanned aircraft have also
been included (Annex 1 to Section 3, Chapter 1).
Expanded guidance regarding the reporting of incidents/occurrences involving the

operation of unmanned aircraft has also been included; such reporting is viewed as being
a vital element in the successful development of the 'fledgling' civilian UAS industry.
Finally, in line with continued developments in UAS terminology, and the principle that
unmanned aircraft are still to be treated as aircraft rather than as a separate entity. In line
with this, the term 'pilot' (i.e. the person who operates the controls for the aircraft) is used

more frequently. The term 'Remotely Piloted Aircraft' (RPA) is also emerging in some
areas, although it has not yet been wholeheartedly accepted for use in the UK.
Third Edition 28 April 2008

Introduction
Following discussions at the CAA Unmanned Aircraft Systems (UAS) Working Group, held
on 12 October 2006, it was considered that sufficient progress had been made in many
areas of UAS work to warrant a substantial review of CAP 722. In particular, as an
upsurge in UAS activity is envisaged over the coming years it is essential that both
industry and the CAA, as the regulatory body, clearly recognize the way ahead in terms of
policy and regulations and, more importantly, in safety standards.
With an ever-increasing number of manufacturers and operators, it is vital that the

regulations keep pace with UAS developments, without losing sight of the safety issues
involved in the simultaneous operation of manned and unmanned aircraft. As a living
document, it is intended that CAP 722 will be under constant review and that it will be
revised, where necessary, to take account of advances in technology, feedback from
industry, recognised best practice and changes in regulations, which are developed to
meet these demands. However, it is recognised that with continual rapid developments
there will inevitably be times when Chapter sponsors will have to be approached directly
for further guidance.
Revisions in this Edition
The layout of the document has been amended to more clearly separate Civil and Military
guidance and as such the Chapters have changed in many areas. In addition, while there
are many minor textual changes to the document, a significant revision has been made in
many areas and as such it is recommended that those involved in UAS operations review
the entire content of the document to ensure that they are fully cognisant with the update.
Impending Changes to Regulation
The CAA is in the process of a consultation with industry over a proposal to amend the Air
Navigation Order which will require operators of UAS with a UAV component of less than 7
kg mass to obtain a CAA permission, as is currently the case for UAVs with a mass of 7-20
kg. This proposal intends to ensure public safety by applying operational constraints to
UAVs of less than 7 kg mass, as deemed appropriate to the type of operation envisaged
and the potential risk to members of the public.
If the consultation exercise approves the proposal, it is likely that the ANO Amendment will
pass into law in December 2008. Potential operators of UAS with a UAV component of
less than 7 kg must ascertain, before commencing operations, whether or not they are
required to obtain a CAA permission.

Third Edition incorporating amendment 2009/01 14 April 2009
This amendment is published in order to update contact details and references throughout
the document and make some editorial corrections.
Second Edition 12 November 2004

The major changes in this document are on legal, certification, spectrum and security
issues.
Details of the CAA Policy on Model Aircraft/Light UAV have also been included.

CAP 722 Foreword
Foreword
Aim
CAP 722, Unmanned Aircraft System Operations in UK Airspace – Guidance and Policy, is
compiled by the Civil Aviation Authority's Unmanned Aircraft Systems Unit (UAS Unit).
CAP 722 is intended to assist those who are involved with the development, manufacture
or operation of UAS to identify the route to follow in order that the appropriate operational
authorisation(s) may be obtained and to ensure that the required standards and practices
are met. Its content is primarily intended for non-recreational UAS operators, but it is
clearly recognised that there is a great deal of overlap with recreational use, particularly
when the smaller (lower mass) unmanned aircraft are concerned; as a result, much of this
guidance is also directly relevant to recreational uses.
Furthermore, the document highlights the safety requirements that have to be met, in
terms of airworthiness and/or operational standards, before a UAS is allowed to operate in
the UK.
In advance of further changes to this document, updated information is contained on the

CAA website 1.
Content
The content of CAP 722 is wholly dependent on contributions from lead agencies; it does
not replace civil regulations but provides guidance as to how civil UAS operations may be
conducted in accordance with those regulations, and the associated policy. Wherever
possible the guidance contained herein has been harmonised with any relevant emerging
international UAS regulatory developments.
It is acknowledged that not all areas of UAS operations have been addressed fully. It is
therefore important that operators, industry and government sectors remain engaged with
the CAA and continue to provide comment on this document.
Availability
The primary method of obtaining a copy of the latest version of CAP 722 is via the CAA
website 2 under the publications section.
1
www.caa.co.uk/uas
2
www.caa.co.uk/CAP722

CAP 722 Foreword
The CAA has a system for publishing further information, guidance and updates. This can
be found within the ‘latest updates’ section of the CAA website’s UAS webpages. In
addition, the CAA also provides a more general aviation update service via the SkyWise
system .
Structure
The UAS Guidance documentation is structured as follows:
CAP722
Chapter 1 General
Chapter 2 Authorisations and Approvals
Chapter 3 Policy
Chapter 4 Airworthiness
Chapter 5 Operations
CAP722 A Operating Safety Cases
Section 1 UAS OSC Volume 1 – Operations Manual Template
Section 2 UAS OSC Volume 2 – UAS Systems Template
Section 3 UAS OSC Volume 3 – Safety and Risk Assessment Guidance and Template
CAP722 B National Qualified Entity

CAP 722 Point of Contact
Point of Contact
Unless otherwise stated, all enquiries relating to CAP 722 must be made to:
For queries relating to the content of CAP 722:
UAS Unit
CAA
Safety and Airspace Regulation Group
Aviation House
West Sussex
RH6 0YR
E-mail: [email protected]
For matters concerning operations or approvals:
Shared Service Centre (UAS)

CAA
Aviation House
West Sussex
RH6 0YR
Telephone: 03300 221908


CAP 722 Abbreviations and Glossary of Terms
Abbreviations and Glossary of Terms
The terminology relating to UAS operations continues to evolve and therefore the
Abbreviations and Glossary of Terms sections are not exhaustive. The terms listed below
are a combination of the emerging ICAO definitions and other 'common use' terms which
are considered to be acceptable alternatives.
Abbreviations
A
AAIB Air Accidents Investigation Branch
ACAS Airborne Collision Avoidance System
ADS-B Automatic Dependent Surveillance Broadcast
AFIS Aerodrome Flight Information Service
AIC Aeronautical Information Circular
AIP Aeronautical Information Publication
ALARP As Low As Reasonably Practicable
AMSL Above mean sea level
ANO Air Navigation Order
ANSP Air Navigation Service Provider
AOC Air Operator Certificate
API Application Programmable Interface
ATC Air Traffic Control
ATM Air Traffic Management
ATS Air Traffic Service
ATSU Air Traffic Service Unit
ATZ Aerodrome Traffic Zone
B
BMFA British Model Flying Association

BRLOS Beyond Radio Line of Sight
BVLOS Beyond Visual Line of Sight
C
CA Congested Area
CAA Civil Aviation Authority
CAT Commercial Air Transport
ConOps Concept of Operations
CRM Crew Resource Management
CS Certification Specification
C2 Command and Control
D
DA Danger Area
DAA Detect and Avoid
DAAIS Danger Area Activity Information Service
DACS Danger Area Crossing Service
DAP Directorate of Airspace Policy
DPG Diplomatic Protection Group
E
EASA European Aviation Safety Agency
EC Electronic Conspicuity
ECCAIRS European Co-ordination Centre for Accident and Incident Reporting Systems
ENSF Enhanced Non Standard Flight (clearance)
ERF Emergency Restriction of Flying
EVLOS Extended Visual Line of Sight
F
FIR Flight Information Region
FISO Flight Information Service Officer
FMC Flight Management Computer

FPV First Person View
FRTOL Flight Radio Telephony Operators’ Licence
FRZ Flight Restriction Zone
G
GCS Ground Control Station
H
HMI Human-Machine Interface
I
ICAO International Civil Aviation Organisation
IFR Instrument Flight Rules
IMC Instrument Meteorological Condition
J
JARUS Joint Authorities for Rulemaking on Unmanned Systems
M
MAA Military Aviation Authority
MOD Ministry of Defence
MOR Mandatory Occurrence Reporting
MTOM Maximum Take-off Mass
N
NAA National Aviation Authority
NOTAM Notice to Airmen
NQE National Qualified Entity
O
OSC Operating Safety Case
P
PPL Private Pilot Licence
R
RA (T) Restricted Area (Temporary)

RCS Radar Cross Section
RLOS Radio Line of Sight
RPA Remotely Piloted Aircraft
RPAS Remotely Piloted Aircraft System
RPS Remote Pilot Station
RPZ Runway Protection Zone
RTF Radiotelephony
RTS Release to Service
S
SARPs Standards and Recommended Practices
SARG Safety and Airspace Regulation Group
SDK Software Development Kit
SERA Standardised European Rules of the Air
SMS Safety Management System
SSR Secondary Surveillance Radar
SUA Small Unmanned Aircraft
SUSA Small Unmanned Surveillance Aircraft
T
TC Type Certificate
TCB Type Certification Basis
TCDS Type Certificate Data Sheet
TCAS Traffic Alert and Collision Avoidance System
TDA Temporary Danger Area
TLOS Target Level of Safety
U
UA Unmanned Aircraft
UAS Unmanned Aircraft System(s)
UAS OSC Unmanned Aircraft System(s) Operating Safety Case

UIR Upper Flight Information Region
V
VFR Visual Flight Rules
VLOS Visual Line of Sight
Glossary of Terms
A
Aircraft - Any machine that can derive support in the atmosphere from the reactions of the
air other than the reactions of the air against the Earth’s surface.
Air Navigation Order (ANO) – The legal document, established as a UK Statutory

Instrument (SI) that is made for the purposes of regulating air navigation within the United
Kingdom.
Autonomous Aircraft - An unmanned aircraft that does not allow pilot intervention in the
management of the flight.
Autonomous Operation - An operation during which an unmanned aircraft is operating

without pilot intervention in the management of flight.
B
Beyond visual line‐of‐sight (BVLOS) operation. An operation in which the remote pilot
or RPA observer does not use visual reference to the unmanned aircraft in the conduct of
flight.
C
Continued Airworthiness - The monitoring, reporting and corrective action processes
used for in-service aircraft to assure they maintain the appropriate safety standard defined
during the initial airworthiness processes throughout their operational life.
Continuing Airworthiness - The system of management of the aircraft and the

scheduling and actioning of ongoing preventative and corrective maintenance to confirm
correct functioning and to achieve safe, reliable and cost-effective operation.
Command and Control (C2) Link - The data link between the remotely-piloted aircraft
and the remote pilot station for the purposes of managing the flight.

Concept of Operations - describes the characteristics of the organisation, system,

operations and the objectives of the user.
Controlled airspace – airspace which has been notified as Class A airspace, Class B
airspace, Class C airspace, Class D airspace or Class E airspace;
D
Detect and Avoid - The capability to see, sense or detect conflicting traffic or other
hazards and take the appropriate action.
E
Electronic Conspicuity - Electronic Conspicuity (EC) is an umbrella term for a range of
technologies that can help airspace users to be more aware of other aircraft in the same
airspace.
F
Flight Restriction Zone (FRZ)- A zone around a protected aerodrome which prohibits the
flight of UAS unless permission from relevant ATS unit is obtained.
G
Ground Control Station (GCS) - See ‘Remote Pilot Station’.
Note: RPS is the preferred term as it enables the consistent use of one term with the same
meaning irrespective of its location (e.g. on a ship or in another aircraft).
H
Handover - The act of passing piloting control from one remote pilot station to another.
High Authority - those systems that can evaluate data, select a course of action and
implement that action without the need for human input.
Highly Automated - those systems that still require inputs from a human operator (e.g.
confirmation of a proposed action) but which can implement the action without further
human interaction once the initial input has been provided.
I
Initial Airworthiness - The system used to determine the applicable requirements and
establish that an aircraft design is demonstrated to be able to meet these requirements.

Lost C2 Link - The loss of command and control link with the remotely-piloted aircraft
such that the remote pilot can no longer manage the aircraft’s flight.
M
Model Aircraft - Any small unmanned aircraft which is being used for sport or
recreational purposes only.
N
National Qualified Entity – A person or organisation approved by the CAA to submit
reports relating to pilot competence in operating a small unmanned aircraft.
O
Operator - A person, organisation or enterprise engaged in or offering to engage in an
aircraft operation.
Note: In the context of remotely-piloted aircraft, an aircraft operation includes the remotely-
piloted aircraft system.
Operating Safety Case – Methodology used to apply to the CAA for a Permission or
Exemption to operate a UAS within the UK.
Operational Authorisation – A document issued by the CAA that authorises the

operation of an unmanned aircraft system, subject to the conditions outlined within the
authorisation, having taken into account the operational risks involved.
P
Pilot - The person in direct control of the UA - See also ‘Remote Pilot’.
Permission – Authorisation issued by the CAA to allow flights within the UK subject to the
conditions and limitations specified.
R
Radio Line-Of-Sight (RLOS) - A direct radio link point-to-point contact between a
transmitter and a receiver.
Redundancy - The presence of more than one independent means for accomplishing a
given function or flight operation.
Remote Pilot - A natural person responsible for safely conducting the flight of an
unmanned aircraft by operating its flight controls, either manually or, when the unmanned
aircraft flies automatically, by monitoring its course and remaining able to intervene and
change the course at any time. Regulation (EU) 2018/1139

Note: Within ANO 2016, article 94G the “remote pilot”, in relation to a small unmanned
aircraft, is an individual who—
(i) operates the flight controls of the small unmanned aircraft by manual use of
remote controls, or
(ii) when the small unmanned aircraft is flying automatically, monitors its course
and is able to intervene and change its course by operating its flight controls
In this document, the term ‘remote pilot’ is used for all sizes of unmanned aircraft, hence
the first definition is applicable.
Remote Pilot Station (RPS) - The component of the remotely-piloted aircraft system
containing the equipment used to pilot the remotely-piloted aircraft.
Remotely-Piloted Aircraft (RPA) - An unmanned aircraft which is piloted from a remote

pilot station.
Remotely-Piloted Aircraft System (RPAS) - A remotely piloted aircraft, its associated

remote pilot station(s), the required command and control links and any other components
as specified in the type design.
RPA Observer - A trained and competent person designated by the operator who, by
visual observation of the remotely-piloted aircraft, assists the remote pilot in the safe
conduct of the flight.
Runway Protection Zone – A zone, which comprises part of the UAS Flight Restriction
Zone, defined and established for the protection of aircraft along the extended centreline of
the runway.
S
Safety - The state in which risks associated with aviation activities, related to, or in direct
support of the operation of aircraft, are reduced and controlled to an acceptable level.
Safety Management System (SMS) - A systematic approach to managing safety,

including the necessary organizational structures, accountabilities, policies and
procedures.
Sense and Avoid - See ‘Detect and Avoid’.
Small Unmanned Aircraft - Any unmanned aircraft, other than a balloon or a kite, having
a mass of not more than 20 kg without its fuel but including any articles or equipment
installed in or attached to the aircraft at the commencement of its flight.
Small Unmanned Surveillance Aircraft - A small unmanned aircraft which is equipped to

undertake any form of surveillance or data acquisition.
Swarming – Operation of more than one UAS, which are controlled collectively rather than
individually.

T
Tethered Unmanned Aircraft – An unmanned aircraft that remains securely attached
(tethered) via a physical link to a person, the ground or an object at all times while it is
flying. The tether normally takes the form of a flexible wire or a cable and may also
include the power supply to the aircraft as well.
Transponder Mandatory Zone - Airspace of defined dimensions wherein the carriage

and operation of pressure-altitude reporting transponders is mandatory
U
Unmanned Aircraft (UA) - Any aircraft operating or designed to operate autonomously or
to be piloted remotely without a pilot on board.
Note: RPA is considered a subset of UA.
Unmanned Aircraft System (UAS) - An unmanned aircraft and the equipment to control it
remotely.
Note: The UAS comprises individual 'System Elements' consisting of the Unmanned
Aircraft (UA) and any other System Elements necessary to enable flight, such as a
Remote Pilot Station, Communication Link and Launch and Recovery Element. There may
be multiple UAs, RPS or Launch and Recovery Elements within a UAS.
Unmanned Aircraft System operator – Any legal or natural person operating or

intending to operate one or more UAS.
V
Variation – Change of an operation or technical data that requires an application to the
CAA.
Visual Line-Of-Sight (VLOS) Operation - An operation in which the remote pilot or RPA
observer maintains direct unaided visual contact with the unmanned aircraft.

CHAPTER 1 | General
CAP 722 Chapter 1 | General Introduction
Introduction
1.1. Policy
It is CAA policy that UAS operating in the UK must meet at least the same safety and
operational standards as manned aircraft. Thus, UAS operations must be as safe as
manned aircraft insofar as they must not present or create a greater hazard to persons,
property, vehicles or vessels, whilst in the air or on the ground, than that attributable to the
operations of manned aircraft of equivalent class or category.
The CAA will supplement CAP 722 with further written guidance when required For the
purpose of UAS operations, the 'See and Avoid' principle employed in manned aircraft is
referred to as 'Detect and Avoid'.
1.2. Scope
The guidance within CAP 722 concerns civilian unmanned aircraft and UAS as they are
defined in the Glossary of Terms. It primarily focuses on the aspects connected with
unmanned aircraft that are piloted remotely, whilst acknowledging the potential for
autonomous operations in the future.
Military Systems are regulated by the Military Aviation Authority (MAA). All enquiries
regarding military RPAS must be made to:
Military Aviation Authority
Juniper Building
Abbey Wood (North)

Bristol, BS34 8QW
Email: [email protected]
website: www.gov.uk/government/organisations/military-aviation-authority
Similarly, the guidance for operating model aircraft for sporting and recreational purposes
is not included, this guidance is published in CAP 658: Model Aircraft: A Guide to Safe
Flying.

CAP 722 Chapter 1 | General Legal Considerations
Legal Considerations
2.1. The Chicago Convention
As a signatory to the Chicago Convention and a member of ICAO, the United Kingdom
undertakes to comply with the provisions of the Convention and Standards contained in
Annexes to the Convention save where it has filed a Difference to any of those standards.
Article 3 of the Convention provides that the Convention applies only to civil aircraft and
not to State aircraft. State aircraft are defined as being aircraft used in military, customs
and police services. No State aircraft may fly over the territory of another State without
authorisation. Contracting States undertake when issuing Regulations for their State
aircraft that they will have due regard for the safety of navigation of civil aircraft.
Article 8 of the Convention provides that no aircraft capable of being flown without a pilot
shall be flown without a pilot over the territory of a Contracting State without special
authorisation by that State.
Article 8 of the Convention also requires that “each contracting State undertake to ensure
that the flight of such aircraft without a pilot in regions open to civil aircraft shall be so
controlled as to obviate danger to civil aircraft”.
2.2. European Regulation
Regulation (EU) 2018/1139 (the EASA Basic Regulation - BR) sets out common rules for
civil aviation and establishes the European Aviation Safety Agency (EASA). It makes
provision for Implementing Rules, Implementing Acts or Delegated Acts dealing with
airworthiness certification, continuing airworthiness, operations, pilot licensing, air traffic
management and aerodromes.
Neither the BR nor the Implementing Rules apply to aircraft carrying out military, customs,
police, search and rescue, firefighting, coastguard or similar activities or services (State
aircraft). EU Member States must, however, ensure that such services have due regard as
far as practicable to the objectives of the EASA Regulation.
Certain categories of civil aircraft are also exempt from the need to comply with the BR
and its Implementing Rules. These exempt categories are listed in Annex I to the BR
(Annex I aircraft) and primarily consist of manned aircraft categories. The exempt
categories which are of relevance for UAS are:
 tethered aircraft with no propulsion system, where the maximum length of the tether
is 50 m, and where:

 the MTOM of the aircraft, including its payload, is less than 25 kg, or
 in the case of a lighter-than-air aircraft, the maximum design volume of the

aircraft is less than 40 m3;
 tethered aircraft with a MTOM of no more than 1 kg.
The essential requirements for unmanned aircraft are contained within Annex IX of the BR.
An aircraft which is not required to comply with the Basic EASA Regulation, either because
it is a State aircraft or because it comes within one of the exempt categories, remains
subject to national regulation so far as airworthiness certification and continuing
airworthiness are concerned.
Implementing Rules for airworthiness certification and continuing airworthiness have been
in force for some years. The Implementing Rules for pilot licensing, operations,
aerodromes and air traffic management have more recently become applicable. The
CAA’s website contains up to date information concerning these matters.
Implementing Rule (Regulation (EU) 923/2012) is also in force introducing Common Rules
of the Air (the Standardised European Rules of the Air [SERA]). These are supplemented
by the UK Rules of the Air 2015.
Specific EU regulations covering UAS have been developed; these consist of the
Implementing and delegated regulations. Both of these are in force however currently only
the delegated regulation is applicable. The Implementing regulation becomes applicable in
July 2020. Until these regulations are applicable, the national regulations of individual
Member States must be followed. The Implementing and delegated regulations are
described in CAP1789.
In the case of the United Kingdom, the national regulations are as described below.
2.3. National Regulation
This section describes UK national regulation applicable to unmanned aircraft.
2.3.1. Definition of a Small Unmanned Aircraft
Schedule 2 of the ANO defines a Small unmanned aircraft as follows:
“any unmanned aircraft, other than a balloon or a kite, having a mass of not more than
20kg without its fuel but including any articles or equipment installed in or attached to the
aircraft at the commencement of its flight;”
Although not specified in the ANO, the CAA adopts the following definitions:

‘unmanned aircraft’ means any aircraft operating or designed to operate autonomously or

to be piloted remotely without a pilot on board;
‘aircraft’ means any machine that can derive support in the atmosphere from the reactions
of the air other than reactions of the air against the earth's surface;
As such, the CAA considers the following as flying ‘objects’ rather than flying ‘machines’,
and so do not fall within the definition of an unmanned aircraft, or a ‘small unmanned
aircraft’:
 Paper aeroplane
 Hand launched glider, but only those with no moveable control surfaces or remote
control link
 Frisbees, darts and other thrown toys.
The mass of an unmanned aircraft is often referred to in the context of: ‘without its fuel but
including any articles or equipment installed in or attached to the aircraft at the
commencement of its flight’.
For the purposes of electrically powered unmanned aircraft, the batteries are considered
as part of the aircraft, and the ‘charge’ is considered as the fuel.
2.3.2. Civil and Military Regulations
In the United Kingdom, there are two regulatory regimes: civil and military. Military
requirements are a matter for the Ministry of Defence. A military aircraft for this purpose
includes any aircraft which the Secretary of State for Defence has issued a certificate
stating that it must be treated as a military aircraft.
Any aircraft which is not a military aircraft must, under United Kingdom aviation safety
legislation, comply with civil requirements. There is no special provision for other types of
non-military State aircraft such as those carrying out police, search and rescue,
firefighting, coastguard or similar activities or services.
2.3.3. The Air Navigation Order 2016
The main civil requirements are set out in the ANO.
The provisions in the ANO concerning equipment requirements, operational rules,

personnel licensing, aerodrome regulation and regulation of air traffic services apply to all
non-military aircraft, organisations, individuals and facilities.

As explained above, insofar as these national requirements concern airworthiness

certification or continuing airworthiness they will only apply to non-military State aircraft
and Annex I aircraft. Such aircraft are exempt from the need to comply with the EASA
Basic Regulation and Implementing Rules and thus remain subject to national regulation.
A non-military State aircraft or an Annex I aircraft registered in the United Kingdom which
is outside the EASA Basic Regulation and Implementing Rules must have a certificate of
airworthiness or a permit to fly issued by the CAA (or be operating under A or B
Conditions) under the ANO, unless it is:
 an unmanned aircraft with an exemption from the ANO issued by the CAA (section
2.5); or
 a ‘small unmanned aircraft’ as defined in the ANO.
2.3.4. Applicability of the ANO to Small UAS
Small unmanned aircraft are exempted from the majority of the provisions of the ANO via
article 23, and hence none of the above requirements apply. Instead, a set of conditions
are included at articles 94, 94A, 94B, 94G and 95 of the ANO, which detail the specific
requirements for the safe flight small unmanned aircraft and take the form of a
proportionately ‘watered down’ version of the essential requirements of the full ANO.
These conditions cover:
 a placement of responsibility on the remote pilot to only fly the aircraft if

reasonably satisfied that the flight can be conducted safely (health, awareness and
competence of the remote pilot, condition and serviceability of the aircraft,
suitability of operating location etc).
 a requirement to only fly the aircraft within visual line of sight, for the purpose of
avoiding collisions.
 specific airspace restrictions: a restriction of flights over or near aerodromes

(FRZ).
 A maximum flying height of 400 ft above the surface, unless permission to fly
higher has been granted by the CAA, or by the aerodrome ATC/AFIS if within an
FRZ.
 a prohibition on flight for the purposes of commercial operations without the

specific permission of the CAA.
 specific restrictions on the use of small unmanned aircraft for surveillance or data
gathering (minimum distances from congested areas, open-air crowds and third
parties (persons of objects).
An additional set of articles (94C, 94D, 94E and 94F) have been created to cover future

requirements regarding the operator registration and remote pilot competence aspects of
small unmanned aircraft, but these elements do not become applicable until 30 November
2019.
In addition to articles 94, 94A, 94B, 94C, 94D, 94E, 94F, 94G and 95 a number of other
articles also apply to small UAS as defined in article 23. Table 1 below shows a summary
of these:
Article Number Description
2 Interpretation
91 Dropping articles for purposes of agriculture etc. and grant of aerial application
certificates
92 Mooring, tethering, towing, use of cables, etc
93 Release of small balloons
239 Power to prohibit or restrict flying
241 Endangering safety of any person or property
257 CAA’s power to prevent aircraft flying (Except 257(2)(a))
253 Revocation, suspension and variation of certificates, licences and other documents
265 Offences and penalties
266 Exemption from Order (other than articles 179,
230, 247, 250, 251, 252, 255, and 267)
269 Certificates, authorisations, approvals and permissions
Table 1 – ANO applicability to small UAS
2.4. Exemptions and Permissions granted by the CAA
A UAS which is subject to national regulations and which weighs more than 20 kg is not a
'small unmanned aircraft' for the purposes of the ANO. Therefore, all of the requirements
within the ANO (certificate of airworthiness or permit to fly, licensed flight crew etc) must
be complied with. In such circumstances, the CAA may be prepared to issue an exemption
to articles in the ANO (as prescribed in Article 266 of the ANO 2016), other than articles
179, 230, 247, 250, 251, 252, 255, and 267, or any regulations made under this Order, any
aircraft or persons or classes of aircraft or persons, subject to such conditions it deems
appropriate.

An exemption is used to allow an exception to the established law. Such an exception is

usually only made subject to a number of additional conditions which still ensure adequate
safety of the operation.
A permission is used where the established law prevents or restricts an activity but has
set aside the possibility for the activity to take place under certain circumstances. As with
an exemption, a permission would only be granted subject to any conditions which still
ensure adequate safety is maintained.
Under ANO 2016, small unmanned aircraft operations require a permission from the CAA
in the following circumstances:
 flights for the purposes of commercial operations - article 94(5)
 flights at a height of more than 400 ft above the surface - article 94A
 flights of small unmanned aircraft equipped to undertake any form of surveillance

or data acquisition within the minimum distances set out in article 95. In
summary, these are:
 over or within 150 metres of any congested area or an organised open-

air assembly of more than 1000 persons - article 95(2) (a) and (b)
 flights within 50 metres of any person, vehicle, vessel or structure which

is not under the control of the SUA operator or the remote pilot- article
95(2)(c) and (d)
A UAS with a mass greater than 20kg which is not certified can only be operated under the
terms of an exemption issued by the CAA.
2.5. Insurance
Regulation (EC) 785/2004 came into force on 30 April 2005 requiring most operators of
aircraft, irrespective of the purposes for which they fly, to hold adequate levels of
insurance in order to meet their liabilities in the event of an accident. This EC Regulation
specifies amongst other things the minimum levels of third-party accident and war risk
insurance for aircraft operating into, over or within the EU (including UAS) depending on
their Maximum Take-Off Mass (MTOM). Details of the insurance requirements can be
found on the CAA website 3 under “Mandatory Insurance Requirements”.
UK legislation which details insurance requirements is set out in Civil Aviation (Insurance)
Regulations 2005 4.
3
http://www.caa.co.uk/default.aspx?catid=122&pagetype=90&pageid=4510
4
http://www.opsi.gov.uk/si/si2005/20051089.htm

It is every operator’s responsibility to ensure they have appropriate insurance coverage.

This is a condition of each permission, exemption or any other form of operational
authorisation that is issued by the CAA.
Article 2(b) of EC 785/2004 states that the regulation does not apply to ‘model aircraft with
an MTOM of less than 20kg’. In the absence of any definition of model aircraft within the
regulation, the United Kingdom has interpreted ‘model aircraft’ to mean:
“Any small unmanned aircraft which is being used for sport or recreational purposes only”.
Therefore, for all other types of small unmanned aircraft flight, whether commercial or non-
commercial, appropriate cover that meets the requirements of EC 785/2004 is required.
2.6. Enforcement
Our enforcement strategy has recently changed to better reflect the balance of capabilities
between the CAA and local Police services.
The Police often have greater resources, response times and powers of investigation than
the CAA. To support this, the CAA has now agreed with the Police, in a signed
Memorandum of Understanding that the Police will take the lead in dealing with UAS
misuse incidents, particularly at public events, that may contravene aviation safety
legislation or other relevant criminal legislation. Please report any misuse of UAS offences
to your local Police force.
The CAA’s remit is limited to safety and also to investigate where someone is operating
commercially without a permission or not in accordance with their permission. This does
not include concerns over privacy or broadcast rights.
Breaches of Aviation Regulation legislation must be reported directly to:
Investigation and Enforcement Team
Room 505
CAA House
45-59 Kingsway
London
WC2B 6TE
Privacy issues are covered by the Information Commissioners Office (ICO) and will not be
dealt with by the CAA.

If you have any concerns about UAS being used in your area, either from a safety or
privacy perspective, contact your local police on 101.
CAA Enforcement guidance can be found in CAP 1074.
2.7. Lead Agency
 European Aviation Safety Agency – for civil aircraft which are not exempt from the
EASA Regulation.
 Civil Aviation Authority – for civil aircraft which are subject to national regulation.
 Military Aviation Authority – for United Kingdom military aircraft.
 Department for Transport – for insurance matters.

CHAPTER 2 | Authorisations and Approvals
CAP 722 Chapter 2 | Authorisations and Approvals UAS Classification System
UAS Classification System
1.1. Scope
This chapter gives guidance on the classification philosophy for UAS in the United
Kingdom.
1.2. UAS Classifications
The current framework established and used by the CAA, and other NAAs, classifies
aircraft based on simple discriminants or type (e.g. balloon, fixed or rotary wing) and mass.
This reflects the historic developments in manned aviation – but is not necessarily fully
appropriate for UAS hence the ConOps approach being taken by the UK. However, until
such time as the alternative classification protocols defined in forthcoming EU regulations
become applicable, this system is in place.
Working within this framework means we have very simple categorisations - Table 2
describes these.
Mass Category Mass (kg) Responsible Regulatory Body
Small unmanned aircraft 0-20 National Aviation Authority
UAS > 20 National Aviation Authority or EASA

(depending whether UAS is to be
certificated)
Table 2 - Mass Categories Relating to UAS
Unmanned aircraft of any mass now fall within the remit of the EASA Basic Regulation,
unless they are outside of this due to the exceptions defined in Annex I, or aircraft carrying
out military, customs, police, search and rescue, firefighting, coastguard or similar
activities or services (State aircraft). For non-military State unmanned aircraft and Annex I
unmanned aircraft, the CAA has based the applicable certification requirements,
organisation and operational approvals on those that would be applied by EASA as this
provides maximum alignment and would offer potential operating benefits within Europe.
Specific EU regulations covering UAS are currently being developed. Until these
regulations are in place and applicable, the national regulations contained within the ANO
are to be followed.

CAP 722 Chapter 2 | Authorisations and Approvals UAS Classification System
1.3. Future Classification Development
Work is ongoing within ICAO, EASA and JARUS to formulate internationally recognised
categorisations for UAS. These categorisations are being developed along an operation
centric and risk-based approach, rather than the traditional aviation use of mass as a
discriminator. This approach follows the principle that UAS operations should be regulated
in a manner that is proportional to the risk of the specific operation and is very much in line
with the current UK ConOps approach that is described within this document.

CAP 722 Chapter 2 | Authorisations and Approvals Authorisation Requirements Map
Authorisation Requirements Map
2.1. Scope
This section gives guidance to UAS operators on the approach currently taken by the CAA
to determine the level of assurance and assessment required prior to the issue of a
permission or an exemption.
This section provides top level guidance only and is intended to give the community a
starting point from which to develop understanding of the requirements. Chapter 2, Section
3 of this publication gives detailed policy and guidance on the approach to be taken when
applying for a permission or an exemption.
2.2. Basic Requirements
The CAA ConOps philosophy underpins the authorisation process (and thus authorisation
requirements) and aims to ensure that the public and other airspace users are not
exposed to unacceptable risk introduced by UAS operations.
The CAA approach is to categorise UAS and the intended operations as detailed in Figure
1; all operations will fall into either the Low, Medium or High risk category.
The categories can be broken down in simple terms as follows:
 Low risk category – a low risk UAS operation that is conducted within the defined
limitations of the law (ANO) and can take place without the need for any prior
authorisation from the CAA
 Medium risk category – a UAS operation where an operational authorisation

from the CAA, based on a safety risk assessment, is required prior to the flight(s)
taking place. This operational authorisation may be required because of the
additional risks involved, or because one or more of the operational parameters do
not comply with the defined limitations of the law. In some cases, the operational
authorisation may be granted within a General Permission/Exemption, that details
specific conditions that must be complied with.
 High risk category – a UAS operation that, due to the nature and risk of the
operation or activity, requires a certification of the UAS, the UAS operator, and the
remote pilots (i.e. the ‘traditional’ manned aviation approach).
Figure 1 below describes the change in Operational, Technical, Procedural and Pilot
complexity/competence in relation to each other. The three categories described above

are represented along the complexity axis. As the level of complexity of the operation
increases, so too must either the pilot, technical or procedural complexity. After a point, no
more pilot competence may be acquired, and no more procedural complexity may be
acquired. At this point, a higher level of technical assurance is required in order to operate
in this higher risk area.
There are scenarios that are not described, which will require differing levels of
assessment (for example, a very light UAS operating in a complex environment with an
extremely complex flight management system). It is therefore essential that operators
contact the CAA early in the developmental process with any relevant permission or
exemption applications to ensure that the correct approach is being taken.
Low Risk/Complexity Medium Risk/Complexity High Risk/Complexity

Level of Assurance and Integrity
Level of Complexity
Figure 1 - Simple UAS ConOps Authorisation Requirements Map

Low Risk Medium Risk High Risk

Airworthiness No formal Airworthiness assessment Type Certification Basis agreed
Airworthiness based upon UAS Type Certificate required
Requirements Operating Safety Case Design and Production approval
(UAS OSC) submission required
(elements of design,
Continuing and continued
production, continuing
airworthiness processes assessed
and continued
airworthiness will be
assessed)
No design approval or
production approval or TC
or TCB
Operational No Operational Authorisation based upon Authorisation based upon UAS OSC
Authorisation required; UAS OSC Volume 1, 2 and airworthiness submission; or,
and 3 submission or, for more rigorous assessment based
simpler operations, loosely on AOC type assessment
Authorisation based on
UAS OSC Volume 1
Pilot Nil, or as set out in Evidence of pilot Evidence of pilot competency
Competence ANO competency required equivalent to that of manned aviation
required
Operating Visual Line of Sight Congested Areas Congested Areas; and/or,
Environment Not in densely Complex environment High risk environment; and/or,
populated areas where third party risks are BVLOS, BRLOS etc.; and/or,
Not above 400 feet judged to be higher (e.g. Complex airspace
Very low risk within the prescribed
environment minimum distances)

VLOS, EVLOS, BVLOS
Influencing Low complexity, low Low to medium Highly complex; and/or high mass;
Factors mass, benign complexity and/or,
operating environment Congested areas or Densely populated or high-risk
higher risk environment environment
than ‘low risk’ Overflight of groups of people
Increased mass Complex flight profiles
Swarming or multiple UAs Carriage of Dangerous Goods
under the control of one
operator.
Table 3 - UAS Authorisation Categories

CAP 722 Chapter 2 | Authorisations and Approvals Authorisation to Operate
Authorisation to Operate
3.1. Scope
This section gives guidance on the application requirements and processes to operate
UAS in the UK.
3.2. Introduction
All civil aircraft fly subject to the legislation of the Air Navigation Order 2016 (ANO) and the
associated Rules of the Air Regulations. However, in accordance with its powers under
article 266 of the ANO, the CAA may exempt UAS operators from the provisions of the
ANO and the Rules of the Air, depending on the UA’s potential to inflict damage or injury
and the proposed area of operation. Small Unmanned Aircraft are exempted from most of
the provisions of the ANO and Rules of the Air Regulations by the provisions of article 23,
but in many cases, a permission from the CAA may still be required.
Changes, updates and further information are published on the CAA website 5.
3.3. Operational Authorisations
The CAA may issue an exemption or permission for UA to operate if the applicability
criteria detailed in Table 4 are met and the CAA is satisfied that the UA will be operated
within the constraints stipulated. If a UA is intended for operation outside these constraints,
the applicant must submit a UAS OSC and discuss these issues directly with the CAA.
Aircraft Mass Airworthiness Registration Operational Pilot

Approval Authorisation Qualification
20 kg or less No No (Note 1) Yes (Note 2) Yes (Notes 2, 3 & 4)
Over 20 kg Yes (Note 5) Yes (Note 5) Yes - Yes (Note 4)

Exemption
5
www.caa.co.uk/uas

Aircraft Mass Airworthiness Registration Operational Pilot

Approval Authorisation Qualification
Any Mass – High risk EASA approval; or, CAA Yes Yes Yes (Note 4)
category approval in certain cases
(e.g. Annex I aircraft)
Table 4 - Prerequisites for Operating a UA
Notes:
1. ANO 2016 article 94D introduces a requirement for registration of the SUA operator
[for small unmanned aircraft of 250g or greater] from 30 November 2019)
2. Permission is required for:
 aircraft used for Commercial Operations (article 94[5])
 surveillance aircraft flown over or within 150 m of a congested area or open-air

assemblies (article 95)
 surveillance aircraft flown close to people or property (article 95)
 aircraft flown above 400 ft (article 94A)
Exemption required for aircraft flown beyond the direct unaided visual contact of the
remote pilot. (article 94[3])
3. ANO 2016 article 94F introduces a requirement for remote pilots [of small unmanned
aircraft of 250g or greater] to hold an acknowledgement of competency issued by the
CAA from 30 November 2019)
4. Equivalent pilot experience will be considered on a case-by-case basis during

application for an operating permission.
5. It may be possible to obtain certain exemptions from the airworthiness and registration
requirements based on the mitigation within a safety case.
A summary of the permission and exemption framework is described in the figure below.
The most basic regulations are set out in the Air Navigation Order and apply to everyone.
Policy is then ‘layered’ on top of this, permitting or exempting more complex operations
with a higher associated level of risk.

Exemption- EVLOS Exemption- +20Kg Exemption- BVLOS

Complexity of Operation and/or associated risk
Non Standard
Non Standard Permission (Reduced Distances)
Permission (>400 ft)
'Standard Permission' Commercial Operations and congested area
General Exemptions and Permissions
Air Navigation Order 2016 (As Amended)
General public
A CAA permission or exemption only addresses the flight safety aspects of the UAS
operation and does not constitute permission to disregard the legitimate interests of other
statutory bodies such as the Police and Emergency Services, the Highway Agency, Data
Commission, Transport for London or local authorities.
The diagram below sets out the areas in which UAS may not be flown, without a
permission. This diagram is repeated in the sections below and adjusted for each
permission discussed.
400 ft
150 m 50 m
Open air assembly of more than 150 m
Congested area Person, Vessel 1000 people
Vehicle, Structure
Figure 2 – Schematic of areas normally prohibited for small UAS flight, without permissions and exemptions

3.3.1. ‘Standard Permission’
The CAA-issued ‘Standard Permission’ enables a person to conduct commercial

operations with a small unmanned aircraft and also permits operations within a congested
area. Potential operators are required to provide evidence of pilot competence and an
Operations Manual which details how the flights will be conducted. The permission
document no longer contains any division at the 7kg mass boundary. ‘Standard’
permissions will not list specific types (models) but will grant permission to fly any small
unmanned aircraft (SUA) within one or both of the following classes:
 SUA multirotor with a maximum take-off mass (MTOM) not exceeding 20 kg.
 SUA fixed-wing with a MTOM not exceeding 20 Kg.
Note: This classification includes hybrid or VTOL aircraft.
Within each class, the applicant will be free to vary or add SUA as they wish without the
requirement to undertake a practical flight assessment for each individual machine or
when adding or changing to a new type (model). Both categories of NQE (Section 5 of this
chapter) should make their recommendations to the CAA in one or both of the above
classes. However, the applicant will be required to update all necessary manuals to reflect
the models being used within the terms of their permission.
400 ft
50 m
150 m
Person, Vessel
Vehicle or Structure Open air assembly of more than 1000 people
Figure 3 – Schematic of areas normally prohibited for small UAS flight, with a standard permission
With this permission, a UAS may now be flown within a congested area, but not within 50
m of people, vessels, vehicles or structures within this area, and not over or within 150 m
of an open air assembly of more than 1000 people, and not above 400 ft.

Congested Area Operations
Article 95 of the ANO states that operations over or within 150 m of a congested area are
prohibited unless a permission has been issued by the CAA. As such, applicants who wish
to undertake operations within a congested area must apply for a permission to do so. This
permission is often referred to as the ‘standard permission’ and is combined with the
permission to undertake commercial operations (article 94(5)). In this case, a safety case
is not required, but the applicant must submit an operations manual (OSC Volume 1),
evidence of pilot competency and evidence of appropriate insurance cover.
3.3.2. Reduced Distance Operations
Article 95 of the ANO states that operations within 50 m of any vehicle vessel or structure,
or uninvolved person are prohibited unless such a permission is held. Applicants who wish
to undertake operations within these distances must therefore apply to the CAA for this
permission. This must include a safety case including a risk assessment which
demonstrates that the operation can be conducted in a safe manner. An operator may
apply, utilising the UAS OSC, to the CAA to have their existing ‘standard’ permission
varied in order to permit a reduction of the above operating distances- see CAP722A.
With this permission, on top of an existing ‘standard permission’, a UAS may be flown at a
distance less than 50 m to people, vessels, vehicle or structures, within a congested area
and less than 150 m from an open air assembly of more than 1000 people. The UAS may
not be flown over the open air assembly of more than 1000 people, or above 400 ft.
400 ft
Person, vessel <50 m Open air assembly of more than

1000 people <150 m
Vehicle, structure
Figure 4 – Schematic of areas normally prohibited for small UAS flight, with a ‘non standard’ (reduced
distance) permissions

3.3.3. Operations above 400 ft
Operators who wish to fly a small unmanned aircraft at heights greater than 400 ft above
the surface outside an FRZ, are required to apply for a permission from the CAA in
accordance with article 94A and must submit a safety case including a risk assessment
which demonstrates that the operation can be conducted in a safe manner. If this
operation is inside an FRZ, then permission only needs to be sought from the aerodrome,
if the aerodrome has an ATC or AFIS unit. If the operation is inside controlled airspace,
then notification of the flight to the relevant controlling authority may be necessary.
3.3.4. BVLOS and EVLOS Operations
Operators who intend to fly a small unmanned aircraft beyond the direct unaided visual line
of sight of the remote pilot are required to apply for an exemption from article 94(3) and
must submit a safety case including a risk assessment which demonstrates that the
operation can be conducted in a safe manner.
3.3.5. +20 Kg Operations
Operators of unmanned aircraft over 20 kg are required to apply for an exemption from the
CAA. Any commercial operations aspects will also be covered within this exemption. The
application must include a safety case including a risk assessment which demonstrates
that the operation can be conducted in a safe manner.
3.4. Images and other Data Collection Requirements
The provision of images or other data solely for the use of controlling or monitoring the
aircraft is not considered to be applicable to the meaning of 'Surveillance or Data
Acquisition' in relation to ANO 2016 article 95.
UAS operators and remote pilots should be aware that the collection of images of
identifiable individuals, even inadvertently, when using surveillance cameras mounted on
an unmanned aircraft, may be subject to the General Data Protection Regulation and the
Data Protection Act 2018. Further information about these regulations and the
circumstances in which they apply can be obtained from the Information Commissioner’s
Office and website: https://ico.org.uk/for-the-public/drones/
UAS operators must be aware of their responsibilities regarding operations from private
land and any requirements to obtain the appropriate permission before operating from a

particular site. In particular, they must ensure that they observe the relevant trespass laws
and do not unwittingly commit a trespass whilst conducting a flight.
3.5. Meaning of Commercial Operations
A commercial operation is defined in article 7 of ANO 2016 as:
‘a flight by a small unmanned aircraft except a flight for public transport, or any
operation of any other aircraft except an operation for public transport;
 which is available to the public;
or
 which, when not made available to the public,
(i) in the case of a flight by a small unmanned aircraft, is performed under a

contract between the SUA operator and a customer, where the latter has no
control over the remote pilot
or
(ii) in any other case, is performed under a contract between an operator and a
customer, where the latter has no control over the operator,
in return for remuneration or other valuable consideration.’
This article must be carefully considered to determine if any flight will be considered as
commercial operations. The key elements in understanding this term are ‘…any flight by a
small unmanned aircraft…in return for remuneration or other valuable consideration…’
The term ‘available to the public’ should be interpreted as being a service or commodity
that any member of the public can make use of, or actively choose to use, (e.g. because it
has been advertised or offered to someone
Flying operations such as research or development flights conducted ‘in house’ are not
normally considered as commercial operations provided there is no valuable consideration
given or promised in respect of that particular flight.

3.6. Operations
3.6.1. Visual Line of Sight (VLOS)
Operating within Visual Line of Sight (VLOS) means that the remote pilot must be able to
clearly see the unmanned aircraft and the surrounding airspace at all times while it is
airborne. The key requirement of any flight is to avoid collisions and a VLOS operation
ensures that the remote pilot is able to monitor the aircraft’s flight path and so manoeuvre
it clear if anything that it might collide with. While corrective lenses may be used, the use
of binoculars, telescopes, or any other forms of image enhancing devices are not
permitted. Putting things in very simple terms, when operating VLOS, the aircraft must
not be flown out of sight of the remote pilot’s eyes.
Within the UK, VLOS operations are normally accepted out to a maximum distance of 500
metres horizontally from the remote pilot, but only if the aircraft can still be seen at this
distance. The ANO also limits the maximum distance from the earth’s surface to a height
of 400 feet (see para 3.20 below). Operations at a greater distance from the remote pilot
may be permitted if an acceptable safety case is submitted. For example, if the aircraft is
large it may be justifiable that its flight path can be monitored visually at a greater distance
than 500 metres. Conversely, for some small aircraft, operations out to a distance of 500
metres may mean it is not possible to assure or maintain adequate visual contact, and so
the aircraft must obviously be kept closer to the remote pilot.
3.6.2. Operations in Congested Areas
Congested Areas
ANO 2016 Schedule 1 states that a ‘Congested Area’ means any area in relation to a city,
town or settlement which is substantially used for residential, industrial, commercial or
recreational purposes.
Operations of small unmanned aircraft over or within 150 metres of congested areas
require a permission to be issued by the CAA in accordance with article 95(2)(a). Such a
permission will normally be granted provided that the SUA operator is able to produce a
suitable operations manual, evidence of remote pilot competency, and evidence of
appropriate insurance cover. Separation distances from persons, vessels, vehicles and
structures must still comply with the other requirements of article 95 (dependent on
whether or not they are under the control of the remote pilot or the SUA operator).

Protection of Third Parties

Under ANO 2016 article 241, operators of small unmanned aircraft must not recklessly or
negligently cause or permit their aircraft to endanger any person or property. This article
does, of course, also apply to the endangerment of manned aircraft (because they are
‘property’) and the occupants of manned aircraft (because they are still ‘persons’).
Flights within the densely-populated urban environment have a higher probability of

endangering persons or property unless conditions are put on their use so that they reduce
the risk to third parties, i.e. the general public. Small unmanned aircraft do not currently
have any recognised design, certification or other airworthiness standards and therefore
operational restrictions have been established that limit the circumstances and locations at
which the aircraft can be operated. Each specific limitation can only be varied or exempted
in accordance with a permission or exemption granted by the CAA. An SUA operator will
need to apply to the CAA for permission to fly a camera-equipped small unmanned
aircraft:
 Over or within 150 metres of an organised open-air assembly of more than 1,000
persons.
 Within 50 metres of any person, vessel, vehicle or structure which is not under the
control of the SUA operator or remote pilot (during take-off or landing, the distance
from persons ‘not under control’ may be reduced to 30 metres).
Such a permission would be suitable for those SUA operators that find they are frequently
engaged in towns and cities to carry out work for film and TV productions, advertising
agencies, marketing or other publicity events, photographic work for large property
developments or survey or infrastructure inspections at industrial sites, etc. There is no
guarantee that a permission to reduce these distances can be granted.
Persons under the control of the SUA operator or remote pilot

Persons under the control of the SUA operator or remote pilot can generally be defined as:
 Persons solely present for the purpose of participating in the flight operation.
 Persons under the control of the event or site manager who can reasonably be
expected to follow directions and safety precautions to avoid unplanned interactions
with the small unmanned aircraft. Such persons could include building-site or other
industrial workers, film and TV production staff and any other pre-briefed,
nominated individuals with an essential task to perform in relation to the event.
Spectators or other persons gathered for sports or other mass public events that have not
been specifically established for the purpose of the flying operation are not regarded as
being ‘under the control’ of the of the SUA operator or remote pilot.
In principle, persons under the control of the SUA operator or remote pilot at a mass public

event must be able to:
 elect to participate or not to participate with the small unmanned aircraft flight
operations;
 understand the risk posed to them inherent in the small unmanned aircraft flight
operations;
 have reasonable safeguards instituted for them by the site manager and SUA
operator during the period of any flight operations;
 not have restrictions placed on their engagement with the purpose of the event or
activity for which they are present if they do not elect to participate with the small
unmanned aircraft operation.
Note: As an example, it is not sufficient for persons at a public event to have been
informed of the operations of the small unmanned aircraft via such means as public
address systems, website publishing, e-mail, text and electronic or other means of
ticketing, etc. without being also able to satisfy the points above. Permissions have,
however, occasionally been granted for small unmanned aircraft flights at public
events where these involved a segregated take-off site within the main event, with
the aircraft operating only vertically within strict lateral limits that keep it directly
overhead the take-off site. Such flights may also be limited by a height restriction
and the tolerance of the aircraft to wind effects and battery endurance.
Further guidance on operational factors for small unmanned aircraft flights can be found in
CAP 722A Annex A.
Vehicles, Vessels and Structures under the control of the SUA operator or remote
pilot
Article 95(2)(c) makes reference vessels, vehicles and structures being under the control
of a remote pilot or operator.
A vessel or vehicle could be said to be ‘under the control’ of a person if:

 That vehicle or vessel is present for the purpose of participating in the flight
operation; and
 The operator of the vehicle or vessel (for example the driver of a car or captain of a
ship) and any passengers are under the control of the remote pilot and can
reasonably be expected to follow directions and safety precautions to avoid
unplanned interactions with the small unmanned aircraft; and
 The owner or other person with an interest in the vessel or vehicle (such as a
lessee) has granted permission for a UAS to operate within 50 metres of that
vehicle or vessel.

A structure could be said to be ‘under the control’ of a person if:

 The owner or other person with an interest in the structure (such as a lessee) has
granted permission for a UAS to operate within 50 metres of that structure; and
 Any occupants of the structure are under the control of the remote pilot.
3.6.3. Extended Visual Line of Sight (EVLOS)
EVLOS operations are operations, either within or beyond 500 metres / 400 feet, where
the remote pilot is still able to comply with their collision avoidance responsibilities, but the
requirement for the remote pilot to maintain direct visual contact with the UA is addressed
via other methods or procedures. It is important to note, however, that collision avoidance
is still achieved through the ‘visual observation’ of a human (by the remote pilot and/or
competent Observers).
EVLOS operations may only be conducted under the terms of an exemption issued by the
CAA. The operator must submit a safety case including a risk assessment for the
operation. Factors taken into consideration must include:
 the procedures for avoiding collisions;
 aircraft size;
 aircraft colour and markings;
 aircraft aids to observation;
 meteorological conditions and visibility, including background conditions (cloud /

blue sky);
 the use of deployed observers, including suitable communication methods within

the team; and
 operating range limits - suitable radio equipment must be fitted in order to be able
to effect positive control over the UA at all times.
3.6.4. Beyond Visual Line of Sight (BVLOS)
Operation of a UA beyond a distance where the remote pilot is able to respond to or avoid
other airspace users by visual means is considered to be a BVLOS operation.
UA intended for BVLOS operations will require either:
 A technical capability which has been accepted as being at least equivalent to the
ability of a pilot of a manned aircraft to ‘see and avoid’ potential conflictions. This is
referred to as a Detect and Avoid (DAA) capability.

 Any DAA capability would be expected to ensure compliance with

Regulation (EU) 923/2012 the Standardised European Rules of the Air
(SERA) chapter 2 6 (avoidance of collisions), as adjusted by Rule 8 of
the Rules of the Air Regulations 2015 (Rules for avoiding aerial
collisions);
 a block of airspace to operate in which the unmanned aircraft is ‘segregated’ from

other aircraft - because other aircraft are not permitted to enter this airspace block,
the unmanned aircraft can operate without the risk of collision, or the need for other
collision avoidance capabilities; or
 clear evidence that the intended operation will pose ‘no aviation threat’ and that the
safety of persons and objects on the ground has been properly addressed
Note: the ultimate responsibility for avoiding collisions lies with the Remote Pilot,
irrespective of the flight rules that the flight is being conducted under or any ATC
clearances that may have been issued.
3.6.5. VLOS operating heights
Visual Line of Sight operations are limited to a maximum height restriction of 400 feet
above the surface, however there is scope for the CAA to authorise flight at greater
heights, via either a permission or exemption, if the CAA is satisfied that this can be
achieved safely. Operations above 400 feet, within an aerodrome FRZ, may be approved
by the Aerodrome Air Traffic Control service or Flight Information Service, without CAA
approval.
This height limitation is intended to contribute to the safety of manned aircraft from the risk
of collision with a small unmanned aircraft. With the obvious exception of take-off and
landing, the majority of manned aircraft fly at heights greater than 500 ft from the surface.
While there are some other exceptions where manned aircraft fly at ‘low level’ (such as
Police, Air Ambulance and Search and Rescue helicopters, as well as military aircraft),
flying a small unmanned aircraft below 400 ft significantly reduces the likelihood of an
encounter with a manned aircraft. The height limitation is also identical to the one that is
being introduced within the forthcoming European regulations for the operation of
unmanned aircraft.
In aviation terms, ‘height’ means the vertical distance of an object (in this case the
unmanned aircraft) from a specified point of datum (in this case above the surface of the
earth). To cater for the few occasions where a small unmanned aircraft is being flown over
hilly/undulating terrain or close to a cliff edge, the 400 ft height above the surface
requirement may be interpreted as being a requirement to remain within a 400 ft distance
6
In particular SERA 3201, SERA 3205, SERA 3210 and SERA 3215

from the surface, as shown in Figure 2 below. For the purposes of article 94A, this is
considered to be an acceptable means of compliance with the legal requirement.
Figure 5 – VLOS 400 ft above the surface interpretation
It should be noted that the 400 ft limitation applies to ‘heights above/distances from’ the
surface of the earth. It does not automatically apply to heights/distances from tall buildings
or other structures: in such cases, an additional permission from the CAA will be required,
which will invariably also require permission to operate within a congested area
3.6.6. VLOS operations at night
There are no specific prohibitions to VLOS operations during night time. The basic VLOS
principles still apply (i.e. you must be able to see the aircraft and the surrounding
airspace). However, any applications for operational authorisations which include VLOS
flight at night will be expected to include a ‘night operations’ section within the operations
manual which details the operating procedures to be followed and should include items
such as:
 daylight reconnaissance and site safety assessment of the surrounding area
 identification and recording of any hazards, restrictions and obstacles
 illumination of the launch site
 aircraft lighting/illumination requirements
 weather limitations for operation

3.6.7. Tethered UAS operations
A tethered UAS operation is one where the unmanned aircraft remains securely attached
(tethered) via a physical link to a person, the ground or an object at all times while it is
flying. The tether normally takes the form of a flexible wire or a cable and may also
include the power supply to the aircraft as well.
Operations with a tethered UAS can be used as an efficient solution in a number of cases,
for example where an operating area is restricted, or when the required flight time exceeds
the normal endurance of a free flying battery powered aircraft.
Tethered UAS are subject to the same basic operating regulations as all other unmanned
aircraft and, where necessary, are subject to the same authorisation process, but the fact
that the operation is tethered can be used as a significant mitigation factor when applying
for an operating authorisation, thus greatly simplifying the overall process.
3.7. Insurance
UAS Operators must comply with Regulation (EC) 785/2004 on Insurance Requirements
for Air Carriers and Aircraft Operators. Further details regarding insurance are contained in
Chapter 1, Section 2.5.
3.8. UAS Operating Safety Case (OSC)
The UAS Operating Safety Case (UAS OSC) has been devised using the ConOps
methodology to give a flexible method by which the applicant can provide the CAA with a
safety argument for intended operations. Each application for an exemption or a
permission (other than for a ‘standard permission’ for commercial operations and/or for
operations within a congested area) must be accompanied by a UAS OSC. Guidance and
templates for the separate volumes of the UAS OSC are contained within CAP 722A.
Table 5 below provides UAS OSC requirements when applying for an exemption or
permission.
Mass (kg) Operating examples Volume 1 Volume 2 Volume 3
20 kg or less ‘Standard Permission’ Required Recommended Recommended

(commercial ops and/or
<150 m in congested area)

Mass (kg) Operating examples Volume 1 Volume 2 Volume 3
<50 m from uninvolved Required Required Required

people/properties;
<150 m from ‘organised

open-air assemblies of
more than 1000 persons’;
>400 ft above the surface
EVLOS
BVLOS
over 20kg Low Complexity UAS Required Required Required

and/or
Rural Environment
Low Complexity UAS Required Required Required
and/or
Semi-rural 7
High Complexity UAS Required Required Required
and/or
Complex Airspace 8/
Congested Area
Table 5 – UAS OSC Authorisation Requirements
Further details can be found in CAP722A.
7
May require more formal airworthiness certification
8
May require more formal airworthiness certification within Category C (Certified)

CAP 722 Chapter 2 | Authorisations and Approvals Application Process
Application Process
In order to ensure that sufficient safety measures have been put in place, operators that
are required to apply for permission from the CAA will be asked to demonstrate that they
have considered the safety implications and taken the steps necessary to ensure that the
UA will not endanger anybody.
It is important to understand that it is the SUA operator (defined in ANO 2016 article 94G -
i.e. the person having management of the UA, and not another person who may, for
example, have contracted with the operator to have work done) who must apply for an
exemption or permission.
Applications for an operational authorisation (exemption or permission) must be made

using the application process listed in the UAS webpages of the CAA website
www.caa.co.uk/uas .
The applicant is then able to apply through the NQE or directly to the CAA for the grant of
a CAA ‘standard’ permission that will allow flights for commercial purposes and/or within
congested areas. The operations manual (ideally in electronic PDF format) should
accompany the formal application via the online portal along with electronic copies of the
critical evidence of pilot competency and the correct fee as detailed in the published CAA
Scheme of Charges. The online portal can be found here:
https://apply.caa.co.uk/CAAPortal/servlet/SmartForm.html?formCode=UAS
Please note that the CAA is unable to accept documents stored and hosted in third party
cloud servers.
Applicants must submit all supporting documentation at time of application in support of

this process. Failure to submit all required documentary evidence will delay the
assessment process.
All applications for a permission, exemption or approval will require payment of the
necessary fees as defined in the CAA Scheme of Charges. This can be found on the CAA
website under the Publications Section, CAA Scheme of Charges (General Aviation). Any
Service Level Agreements (SLA) are published on the CAA website and application forms.

CAP 722 Chapter 2 | Authorisations and Approvals National Qualified Entities
National Qualified Entities
A National Qualified Entity (NQE) is approved by the CAA under the authority of Article
268 of the ANO 2016 and as such the approval is bounded by the limits of UK legislation.
The CAA approves National Qualified Entities (NQEs) to conduct assessments of SUA
operators and remote pilots and make recommendations to the CAA based upon these
assessments. The NQE will validate the submission and then forward a recommendation
for the granting of a ‘standard’ permission to the CAA. Further information regarding NQEs
can be found in CAP722B.

CAP 722 Chapter 2 | Authorisations and Approvals Regulatory Enforcement
Regulatory Enforcement
The CAA takes breaches of aviation legislation seriously and will seek to prosecute in
cases where dangerous and illegal flying has taken place. However, the Police generally
has greater resources, response times and powers of investigation than the CAA. To
support this, the CAA has agreed with the Police, in a signed Memorandum of
Understanding, that the Police will take the lead in dealing with UAS misuse incidents,
particularly at public events, that may contravene aviation safety legislation or other
relevant criminal legislation.
Privacy issues are covered by the Information Commissioners Office (ICO) and will not be
dealt with by the CAA.
More information on the regulation of small unmanned aircraft, including a list of operators
with permission to fly small unmanned aircraft for commercial purposes, is available at
www.caa.co.uk/uas.
6.1. Source Documents
 CAP 393 Air Navigation: The Order and the Regulations.
 CAP 1074 Safety and Airspace Regulation Enforcement Guidance

CAP 722 Chapter 2 | Authorisations and Approvals Civil UAS Remote Pilot Competency
Civil UAS Remote Pilot Competency
7.1. Scope
This section applies to all civil UAS operations in United Kingdom airspace. State (non-
military) operated UAS are expected to comply with this section, unless otherwise directed
by the CAA.
UAS operations conducted for the purposes of testing or are expected to comply with this
section as far as is practicable. However, qualification requirements for remote pilots
engaged in such operations will be assessed by the CAA at the point of submission for an
operational authorisation.
7.2. Policy
The requirements for the licensing and training of United Kingdom civil remote pilots have
not yet been fully developed. It is expected that United Kingdom requirements will
ultimately be determined by ICAO Standards and Recommended Practices (SARPs) and
EASA regulations.
ICAO has developed initial standards for a Remote Pilot's Licence (RPL), but these are
part of a larger SARPS package that will not become applicable until 2022 at the earliest
and will not necessarily apply to the Open and Specific operating categories. Until formal
licensing requirements are in place the CAA will determine the relevant requirements on a
case-by-case basis. In determining whether to permit a person to act as a remote pilot of a
UAS, the CAA will consider a number of factors (based upon the ConOps approach) such
as the type of operation being conducted, pilot experience, maximum aircraft mass, the
system being operated, flight control mode, operational control and safety assessment.
7.3. Maximum Operating Mass
UAS are currently classified into two mass categories described below; the flight crew
qualification requirements are related to these. Table 6 details the competency
requirement for pilots of UAS in the relevant aircraft mass category.

Operating Mass Pilot Competency / Licensing Requirements

(maximum)
20 kg or less None, NQE competency assessment/ AMC , or additional competency

dependent on the requirements of the operation (Operating Safety Case)
Note: from 30 November 2019, ANO article 94F introduces new ‘basic’
competency requirements for remote pilots of small unmanned aircraft
More than 20 kg Dependent on requirements of the operation (Operating Safety Case), RPL,
or equivalent
Table 6 Unmanned Aircraft Mass Related Pilot Competency and Licensing Requirements
7.4. UAS Flight Control Mode
Remote Pilots will also be required to meet training and testing requirements for each
class or type of UAS they will operate. This may be specific to each model of UAS (in the
case of larger and certified platforms) or a more general ‘type’ of UAS – i.e. multi rotor,
fixed wing etc, in the case of smaller UAS.

7.5. Alternative Means of Compliance
Table 7 describes the alternative means of compliance for the demonstration of pilot
competency. NQEs are not under any obligation to accept candidates with these
acceptable means of compliance, in such instances these candidates may present
acceptable means of compliance described below to the CAA, with their practical flight
assessment recommendation.
UAS Pilot (a) (b) (c) (d)

Competency
Alternative
Means of
Compliance
Existing Aviation Critical Element: Critical Element: Critical Element:
Qualification: Theoretical Initial Practical Experience
Knowledge Flight Requirement
Requirement / Assessment (annual renewal)
General Requirement
Airmanship (no requirement
(no requirement for annual
for annual renewal)
renewal)
1 Nil Completion of a Full Category NQE 2 hours total flight
course experience logged
2 Current EASA Fixed- Nil Pilot flight skills within the last 3
Wing, Helicopter or assessment verified calendar months on the
Microlight licence to the CAA by a class of SUA for which
Full or Restricted a Permission is sought.
3 Current UK National Nil
Fixed-Wing, Helicopter Category NQE in at It should be noted that
least one of the these hours must be
or Microlight licence

UAS Pilot (a) (b) (c) (d)

Competency
Alternative
Means of
Compliance
4 UK Military pilot / Nil following two undertaken on a SUA,
remote pilot or RPAS classes: and not an SUA
operator qualification a) SUA multirotor simulator.
(applicable where basic with a maximum Pilots may self-certify
flight training has been take-off mass through logbook entries
carried out in non- (MTOM) not (these can be hard
segregated UK exceeding 20 kg. copy or electronic).
airspace) b) SUA fixed-
RAF VGS Instructor wing with a MTOM
qualifications not exceeding
commencing at G1 20 kg.
Instructor level are also
acceptable
5 British Gliding Nil
Association (BGA) -
Bronze ‘C’ and above
(or EASA equivalent)
6 BMFA ‘A’ or ‘B’ Nil Nil. Helicopter
Certificates (or certificate accepted
SAA/LMA equivalents) for multirotors
7 Non-UK SUA/RPAS
qualification/licence Case-by-case CAA assessment
8 Other lapsed pilot Licences that lapsed prior to 2010 will not
licences or certificates be deemed acceptable for the issue of an
authorisation.
Table 7 - Pilot Competency Criteria for Small Unmanned Aircraft Permission under ANO articles 94 and 95

7.6. Granting of a small unmanned aircraft permission or

exemption – Critical elements for remote pilot competency
In order to grant a permission or exemption, evidence of pilot competency must be

demonstrated. This includes:
Pilot Competency
 Adequate theoretical knowledge/general airmanship;
 Successful completion of a practical flight assessment on the class of SUA that is

being applied for;
Operations Manual
The CAA requires the submission and acceptance of an operations manual in each case
before the Permission itself can be granted. The practical competency assessment will be
based on the contents of the operations manual.
Currency of competency
A minimum amount of recent flying experience on the class of SUA that is being applied
for, on renewal of the permission or exemption.
7.7. NQE Recommendations
The CAA accepts recommendations from approved NQEs in order to grant a ‘standard’
Permission. The traditional NQE route allows an individual with no formal pilot
qualifications or experience to undertake a course which can lead to a recommendation to
the CAA for a grant of a CAA Permission. The courses cover all of the critical elements of
pilot competency mentioned in chapter 2, section 7.6 plus an assessment of the student’s
operational procedures as set out in their operations manual (Vol 1 of the UAS OSC). On
successful completion of the course, the applicant will be granted a certificate or
recommendation by the NQE. Recommendations from NQEs provide the CAA with an
acceptable demonstration of remote pilot competence in order to operate a small
unmanned aircraft. The recommendation can only be made once the NQE is satisfied that
the individual has demonstrated appropriate knowledge of the applicable regulations,
policy and/or the capability to fly the aircraft in accordance with his/her organisation’s
operational procedures.
As the UAS industry has developed, the CAA has been increasingly asked to accept
alternative qualifications and methods of demonstrating pilot competency other than those
provided through the NQE route. Many recent applicants for a permission have formal

aviation qualifications, hobbyist certificates or recent flight experience that are highly
relevant for fulfilling the critical elements set out in paragraph 4.7 above. An analysis of the
critical elements points towards the practical flight assessment as being the single most
essential of the elements as small unmanned multirotor and fixed-wing aircraft have
unique flight and control systems and characteristics. Unless an applicant has already
been objectively assessed by a third-party (such as through the British Model Flying
Association (BMFA) certificate system), then there still exists a need for applicants to
complete this critical element through an independent assessment.
The CAA therefore accepts alternative methods of satisfying the critical elements in
addition to completing a full NQE course. Acceptable alternatives to fulfil the critical
elements (evidence of pilot competency) are shown at Table 7.
7.8. Other Factors
Prior to the implementation of formal UAS Remote Pilot licensing requirements, the CAA
will consider factors such as the arrangements for operational control of a UAS, and the
safety risk assessment of a proposed UAS operation, when considering whether to permit
an application for a person to act as a remote pilot.
7.9. Flight Radio Telephony Operators’ Licence
Remote Pilots wishing to use radiotelephony must ensure that they hold a Flight Radio
Telephony Operators’ Licence (FRTOL) valid for the privileges intended to be exercised.
Further information can be found here:
https://www.caa.co.uk/General-aviation/Pilot-licences/EASA-requirements/General/Flight-
radio-telephony-operator-licence/
The use of radiotelephony on aeronautical band radios for contact with air traffic control,
for the operation of small unmanned aircraft, should be limited to exceptional
circumstances, and as directed by the air traffic service unit with which the remote pilot
needs to communicate. In the vast majority of circumstances, mobile telephone
communication, or non-aeronautical radio communication is sufficient. Permission to
access flight restriction zones should not be made by radiotelephony, unless directed to do
so by the aerodrome.

CHAPTER 3 | Policy
CAP 722 Chapter 3 | Policy CAA Policy on Detect and Avoid Capability
CAA Policy on Detect and Avoid Capability
1.1. Scope
This Chapter offers guidance to industry on how to satisfy the requirements for a Detect
and Avoid functions.
1.2. Introduction
A significant increase in both civil and military UAS flying is anticipated, most of which will
require access to some if not all classes of airspace if it is to be both operationally effective
and commercially viable. To achieve this, UAS will have to be able to display a capability
that is equivalent to the existing safety standards applicable to manned aircraft types,
appropriate to the class (or classes) of airspace within which they are intended to be
operated.
1.3. Aim
The aim of this policy statement is to clarify the position of the CAA in respect of its role in
assisting the UAS industry to find solutions to achieving a capability and level of safety
which is equivalent to the existing 'see and avoid' concept. It is also recognised that the
Detect and Avoid (DAA) capability is only one of a number of requirements that will need
to be addressed for safe operation of UAS, particularly if not operating within segregated
airspace.
1.4. General
Detect and Avoid is a generic expression which is used to describe a technical capability
that is commensurate to the ‘see and avoid’ principle used in manned aviation. The
overriding principle when assessing if proposed UAS DAA functions are acceptable is that
they must not introduce a greater hazard than currently exists for manned aviation. Any
proposed capabilities must, as a minimum, demonstrate an equivalence with those
required for manned aircraft. The UAS must be operated in a way that enables it to
comply with the rules and obligations that apply to manned aircraft, particularly those
applicable to separation and collision avoidance. When operating outside controlled
airspace, manned aircraft rely on ‘see and avoid’ to remain clear of other aircraft. UAS

must employ the same philosophy – i.e. it must detect other aircraft and avoid them-
particularly given the difference in size of most UAS compared to manned aircraft, and the
associated difficulty for a manned aircraft in seeing a UAS with sufficient time to remain
clear.
1.5. Separation Assurance and Collision Avoidance Elements
There are two distinct and potentially independent elements to a DAA capability, as
described below. It must be noted that the remote pilot could act as an element within one
or both of these elements, subject to being able to affect the desired outcome.
The DAA (separation and collision avoidance) capabilities must be able to:
 Detect and avoid traffic (air and ground operations) in accordance with the
Rules of the Air;
 Detect and avoid all airborne objects, including gliders, hang-gliders,

paragliders, microlights, balloons, parachutists etc.;
 Enable the Remote Pilot to determine the in-flight meteorological conditions;
 Avoid hazardous weather;
 Detect and avoid terrain and other obstacles;
 Perform equivalent functions, such as maintaining separation, spacing and

sequencing that would be done visually in a manned aircraft.
1.5.1. Detect Function
The detect function is intended to identify potential hazards (other aircraft, terrain, weather
etc.) and notify the appropriate mission management and navigation systems.
1.5.2. Avoid Function
The avoid function may be split down into two parts:
 Separation Assurance/Traffic Avoidance:

This term is used to describe the routine procedures and actions that are applied to
prevent aircraft getting into close proximity with each other. Any resolution
manoeuvring conducted at this stage must be conducted in accordance with the
Rules of the Air. When flying in airspace where the provision of separation is the
responsibility of ATC, however, the remote pilot must manoeuvre the aircraft in
accordance with ATC instructions, in the same fashion as is done for a manned
aircraft.
 Collision Avoidance:
This is the final layer of conflict management and is the term used to describe any
emergency manoeuvre considered necessary to avoid a collision; such a
manoeuvre may contradict the Rules of the Air or ATC instructions. While the
Remote Pilot would normally be responsible for initiating a collision avoidance
manoeuvre, an automatic function may be required in order to cater for collision
avoidance scenarios where the Remote Pilot is unable to initiate the manoeuvre in
sufficient time, e.g. due to command and control (C2) latency issues or lost link
scenarios.
1.6. Minimum DAA Requirements for Routine Operations
For routine BVLOS operations in non-segregated airspace a DAA capability will always be
required unless the UAS operator is able to provide the CAA with clear evidence that the
operation that is being proposed will pose no hazard to other aviation users.
The minimum level of DAA capability that is required may be adjusted in accordance with
the flight rules under which the UA flight is being conducted and class of airspace that the
UA is being flown in as follows:
IFR flights within controlled airspace (Classes A to E)
 A Collision Avoidance capability will be required
 ATC separates from other traffic (although in Class D and E, the pilot of a
conflicting VFR flight holds the separation responsibility)
 As for manned aviation, a collision avoidance capability is required in case

the ‘normal’ separation provision fails
 If the flight is conducted wholly within controlled airspace where the

operation of a transponder is mandatory, then a collision avoidance
capability that is cooperative (e.g. ACAS) would be acceptable
 If there is any possibility that the UAS will/might leave controlled airspace and enter
non-segregated Class G airspace during the flight (including in an emergency), then
the collision avoidance capability would be required to be a non-cooperative one,

unless there are other airspace measures in place that would still allow a
cooperative system to be used; this includes airspace such as a Transponder
Mandatory Zone, airspace above FL100 (where the operation of a transponder is
required) etc
VFR flights within controlled airspace, or any flight within Class G airspace
 A Separation Assurance/Traffic Avoidance capability and a Collision Avoidance

capability will be required
 The remote pilot is the separator for all conflicts, with the same
responsibilities as the pilot of a manned aircraft
1.7. Research and Development
It is not the role of the CAA to carry out research and development activities; this must be
performed by the UAS industry. The research and development process will include full
and open consultation with the CAA at appropriate stages so that the CAA can provide
guidance on the interpretation of the applicable rules and regulations.
It is strongly recommended that developers of DAA technology for the use of UAS in non-
segregated airspace set up a programme of regular discussion and review of their
research and development activity with the CAA; early engagement is vital in the process.
This will ensure that system developers will have access to the best advice on the
applicable regulations, thereby increasing the likelihood of the ultimate acceptance of any
DAA system by the civil authorities.
UAS designers will need to demonstrate equivalence to the regulatory and airworthiness
standards that are set for manned aircraft.
To ensure that the DAA capability can provide the required level of safety they will be
developed for the various component functions which include threat detection, assessment
of the collision threat, selection of an appropriate avoidance manoeuvre and execution of a
manoeuvre compatible with the aircraft’s performance capabilities and airspace
environment. It is recommended that the System Safety Assessment process be followed
(Chapter 4 Section 4) as this will support determination and classification of the various
hazards and thus the level of integrity that may be required from particular system
approaches.
1.8. Factors for Consideration When Developing a DAA Capability
The CAA does not define the matters to be taken into account for the design of aircraft or
their systems. However, for the guidance of those engaged in the development of DAA
systems, some of the factors that may need to be considered are listed below:

 Ability to comply with the Rules of the Air;

 Airworthiness;
 Control method, controllability and manoeuvrability;
 Flight performance;
 Communications procedures and associated links.
 Security (physical and cyber);
 Emergency actions, reversionary or failure modes in the event of degradation of any
part of the UAS and its associated Control and/or Relay Stations;
 Actions in the event of lost communications and/or failure of on-board DAA
equipment;
 Ability to determine real-time meteorological conditions and type of terrain being
overflown;
 Nature of task and/or payload;
 System authority of operation and control;
 Method of sensing other airborne objects;
 Remote Pilot level of competence;
 Communications with ATS providers, procedures and links with control station;
 Means of launch/take-off and recovery/landing;
 Reaction logic to other airspace objects;
 Flight termination;
 Description of the operation and classification of the airspace in which it is planned
to be flown;
 Transaction times (e.g. including delays introduced by satellite links);
 Address both cooperative and non-cooperative air traffic.
Note: This list above is not exhaustive.

CAP 722 Chapter 3 | Policy CAA Policy on Human Factors in UAS Operations
CAA Policy on Human Factors in UAS Operations
2.1. Scope
This Chapter offers guidance to industry on how to address the human factors issues
associated with the design, operation and maintenance of UAS.
2.2. Introduction
It is recognised by the CAA that Human Factors represent an important aspect of the
design, operation and maintenance of UAS.
The fundamental concepts of Human Factors in aviation are covered by CAP 719.
Additional guidance on human factors issues associated with aircraft maintenance is
provided in CAP 716.
It is important to recognise that the human is an integral element of any UAS operation
and, therefore, in addition to the standard Human Factors issues that relate to aviation
development, operation and maintenance, a number of unique Human Factors issues
associated with remote operation will also need to be addressed.
This guidance outlines a number of Human Factors recommendations related to the

design, production operation and maintenance of UAS flown routinely in UK airspace.
2.3. General
A system of systems approach must be adopted in the analysis, design and development
of the UAS. This approach deals with all the systems as a combined entity and addresses
the interactions between those systems. Such an approach must involve a detailed
analysis of the human requirements and encompass the Human Factors Integration
domains:
 Manpower;
 Personnel;
 Training;
 Human Engineering;
 System Safety;
 Health Hazards;

 Social and Organisational;

 Ergonomics;
 Human-Machine Interface (HMI) Development and Assessment;
 Human Performance, including consideration of workload issues, situation
awareness and distributed cognition of the system, teamwork and group
dynamics and user acceptance and confidence in the system;
 Human Error and Resilience Assessment.
This approach must be applied to all the Human Factors issues identified in this Chapter.
2.4. Design Human Factors
There are two levels of Human Factors issues that need to be addressed for design:
 Human factors that affect design teams
 Design induced remote pilot or maintenance human factors issues
2.5. Human Factors That Affect Design Teams
The set of problems that can initiate Human Factors issues for design teams are not
dissimilar to other environments. These include but are not limited to:
 Insufficient time to perform a task;
 Insufficient training and experience to perform a task;
 Inadequate, incomplete or ambiguous procedures, work instructions;
 Rapid and/or uncontrolled changes to requirements;
 Inappropriate working environments that can lead to distraction (e.g. noisy

offices, multiple demands on individual’s time);
 Fatigue;
 Poor or non-existent working relationships with management and/or other

teams.
 Group dynamics affecting group decision making (e.g. groupthink, risky and
stingy shift in risk-based decisions).
Each of these issues can result in a design team making an error and failing to detect it
before the aircraft or aircraft system enters service. These errors can result in operational
or maintenance problems (system failures, inappropriate maintenance etc) and can even

drive additional human factors issues in other aviation domains such as the flight deck or
maintenance.
Organisations that are developing UAS must ensure that the programme management
aspects of their projects address potential Human Factors issues (e.g. provision of
appropriate work spaces and instructions, effective control of the number of simultaneous
demands made on individuals, effective control of the rate of requirement change,
management of fatigue etc). The means by which this will be achieved must be described
to the authority for any proposed certification project
2.6. Design Induced Remote Pilot Human Factors
The set of design induced remote pilot Human Factors issues includes but is not limited to:
 Non-optimal workspace layout which increases the likelihood of errors.
 Failure to present, late presentation or incomplete presentation of important

information to the RPAS pilot.
Too much or too little information provided to the RPAS pilot so that effective
assimilation is not possible. Incorrect prioritisation of alerts 9 ;
 Insufficient notice of the need to perform a task (possibly related to data

latency);
 Lack of clarity regarding where to find the relevant control instructions

(Standard Operating Procedures, Aircraft Flight Manuals etc);
 Non-obvious system mode changes or mode confusion.
Each of these issues can result in a remote pilot either making an error or failing to detect
an aircraft safety issue.
Organisations that are developing UAS must ensure that any identified potential Human
Factors issues (e.g. management of information to the pilot so that he/she can integrate
this effectively, effective control of the number of simultaneous demands made on remote
pilots etc) are addressed and mitigated as part of the UAS development processes. The
means by which this will be achieved must be described to the authority for any proposed
certification project.
9
Alerts is a generic term that includes warnings, cautions and status messages.

2.7. Design Induced Maintenance Human Factors
The set of design induced maintenance Human Factors issues includes but is not limited
to:
 Incomplete situation awareness (as a result of missing/inadequate information

and/or data latency);
 Information overload/underload;
 Incorrect prioritisation of alerts10;
 Insufficient notice of the need to perform a task (possibly related to data latency);
 Lack of clarity regarding where to find the relevant control instructions (Standard
Operating Procedures, Aircraft Flight Manuals etc);
 Non-obvious system mode changes.
Each of these issues can result in a maintenance error which could result in an aircraft
safety issue.
Organisations that are developing UASs must ensure that any identified potential
maintenance Human Factors issues (e.g. provision of clear and unambiguous task
instructions etc) are addressed and mitigated as part of the UAS development processes.
The means by which this will be achieved must be described to the authority for any
proposed certification project.
2.8. Outstanding Problem Reports
Any outstanding problem reports that are related to the interface between the system and
the remote pilot or maintenance functions must be carefully evaluated in terms of any
potential human factors issues. If the problem is likely to result in Human Factors issues
and it cannot be rectified before the system enters service, then:
 The certification flight or maintenance teams must be informed of the problem and
its likely consequences;
 Where applicable the relevant flight or maintenance documentation must be

updated to ensure that the remote pilots or maintenance team are aware of both the
problem and any action(s) they need to take in order to mitigate it;
10
Alerts is a generic term that includes warnings, cautions and status messages.

 The certification team must be provided with an analysis of the problem, the
necessary resolution and the plan for incorporating that resolution.
2.9. Production Human Factors
The set of problems that can initiate Human Factors issues for production teams is not
 Uncontrolled changes to build specifications;
 Inappropriate working environments that can lead to distraction (e.g. noisy offices,
multiple demands on individual’s time;
 Fatigue.
Organisations that are developing UASs must ensure that their production management
processes address potential Human Factors issues (e.g. provision of appropriate work
spaces and instructions, effective control of the number of simultaneous demands made
on individuals, management of fatigue etc). The means by which this will be achieved will
be described to the authority for any proposed certification project.
2.10. Operational Human Factors
In addition to the “standard” operational Human Factors issues, the physical separation of
the Remote Pilot introduces a number of issues that need to be considered. These include
but are not limited to:
 Degradation of situation awareness due to remote operation and associated lack of

multi-sensory feedback;
 Temporal degradation resulting from data latency, pilot recognition, pilot response
and pilot command latency over the data link requires consideration in the design of
controls and displays;
 The Remote Pilot’s risk perception and behaviour are affected by the absence of
sensory/perceptual cues and the sense of a shared fate with the vehicle;
 Bandwidth limitations and reliability of the data link compromising the amount and
quality of information available to the Remote Pilot and thereby limiting his
awareness of the RPA’s status and position.

It is therefore important to:
 Avoid presenting misleading cues and to consider alternative methods of

representing the UAS data;
 Prioritise relevant data sent over the C2 link to satisfy the needs for all phases of
the operation; and
 Ensure that data link characteristics and performance (such as latency and
bandwidth) are taken account of within the relevant information and status displays
in the Remote Pilot Station (RPS).
2.11. Authority and Control
The Remote Pilot is ultimately responsible for the safe conduct of the aircraft. They will,
therefore, be required to sanction all actions undertaken by the aircraft whether that is
during the planning stage (by acceptance of the flight plan) or during the execution of the
mission via authorisation, re-plans or direct command. Though fully autonomous operation
of a UAS is not currently envisaged, certain elements of a mission may be carried out
without human intervention (but with prior authorisation). A good example of this is the
Collision Avoidance System where, due to possible latency within the C2 link, the Remote
Pilot may not have sufficient time to react and therefore the on-board systems may need to
be given the authority to take control of the aircraft.
This level of independent capability, that must operate predictably and safely when
required, can also be harnessed as a deliberative function throughout the flight. This
supports a change in the piloting role from a low-level ‘hands-on’ type of control to an
effective high-level decision maker. Due to the nature of remote operation, the RPS need
no longer be constrained to follow a traditional cockpit design philosophy and must be
designed to fit the new operator role. Account may be taken of enhanced system
functionality allowing the pilot to control the systems as required via delegation of
authority.
A clear understanding of the scope of any autonomous operation and its automated sub-
systems is key to safe operations. Specific areas that need to be addressed are:
 User’s understanding of the system’s operation;
 Recovery of control after failure of an automated system;
 User’s expertise in manual reversion (they will not necessarily be pilots);
 Boredom and fatigue; and
 Design of the controls, including the design ‘model’, allowing the user to understand
how the different levels of automation operate.

2.12. Ergonomics
The RPS will be the major interface between the Remote Pilot and the aircraft. The advice
contained herein relates to the type of information and the nature of the tasks that would
be undertaken at an RPS, it does not set the airworthiness, technical or security
requirements. The ergonomic standards must ensure that the pilot works in an
environment that is fit for purpose, does not create distractions and provides an
environment that will allow pilots to maintain alertness throughout a shift period.
The ergonomic requirements of ‘hand held’ (VLOS) remote pilot stations must also be
considered. Careful consideration must be given to the environmental conditions that will
be encountered when operating outdoors (excesses in temperature, wet or windy
conditions etc.). The potential for distraction to the pilot is also much greater in this
environment.
2.13. Flight Crew Awareness
A number of sub-systems associated with the operation of a UAS are likely to be complex
in their operation and therefore may very well be automated. The system must provide the
operator with appropriate information to monitor and control its operation. Provision must
be made for the operator to be able to intervene and override the system (e.g. abort take-
off, go around).
2.14. Transfer of Control between Remote Pilots
UAS operations may require the transfer of control to another pilot. This operation needs
to be carefully designed to ensure that the handover is accomplished in a safe and
consistent manner and would be expected to include the following elements:
 Offer of control;
 Exchange of relevant information;
 Acceptance of control; and
 Confirmation of successful handover.
The exchange of information between Remote Pilots (co-located or remotely located) will
require procedures that ensure that the receiving pilot has complete knowledge of the
following:
 Flight Mode;

 UAS flight parameters and aircraft status;
 UAS sub-system status (fuel system, engine, communications, autopilot etc);
 Aircraft position, flight plan and other airspace related information (relevant
NOTAMs etc.);
 Weather;
 The current ATC clearance and frequency in use;
 Positions of any relevant RPS control settings in order to ensure that those of the
accepting RPS are correctly aligned with the transferring RPS.
The transferring pilot will remain in control of the RPA until the handover is complete and
the accepting pilot has confirmed that he is ready to assume control. In addition:
 Procedures to cater for the recovery of control in the event of a failure during the
transfer process will be required; and
 Special attention will be required when designing handover procedures involving a

significant change in the control interface, for example between a VLOS 'Launch
and Recovery Element' RPS and a BVLOS 'En-Route' RPS.
2.15. Crew Resource Management
Workload and Crew Resource Management play an equally important role in the ground
station as they do on a manned flight deck. The allocation and delineation of roles must
ensure a balanced workload and shared situation awareness of the UAS status and
proximity to other aircraft and flight paths to ensure that:
 The display design provides clear and rapid information retrieval matched to the
human needs; and
 The Remote Crew Station design promotes good team co-ordination.
2.16. Fatigue and Stress
Fatigue and stress are contributory factors which are likely to increase the propensity for
human error. Therefore, in order to ensure that vigilance is maintained at a satisfactory
level in terms of safety, consideration must be given to the following:
 Crew duty times;
 Regular breaks;
 Rest periods and opportunity for napping during circadian low periods;

 Health and Safety requirements;
 Handover/Take Over procedures;
 The crew responsibility and workload;
 Ability to mitigate the effects of stress from non-work areas (e.g. financial pressure
causing anxiety).
The work regime across the crew must take this into account.
2.17. Degradation and Failure
Degradation of performance and failures will require a philosophy for dealing with
situations to ensure consistent and appropriate application of warnings, both visual and
auditory. The philosophy must ensure that:
 The design provides good error detection and recovery;
 The design is fail-safe and protects against inadvertent operator actions that could
instigate a catastrophic failure;
 In the event of degraded or total breakdown in the communication link the status of
the lost link will be displayed to the operator. Ideally the expected planned reactions
of the UA to the situation will also be displayed to the operator;
 Operating procedures are designed to be intuitive, not ambiguous and reinforced by

training as required.
2.18. Maintenance Human Factors
The set of problems that can initiate Human Factors issues for maintenance teams is not
 Inappropriate working environments that can lead to distraction (e.g. noisy offices,
multiple demands on individual’s time);
 Fatigue;
 Poor or non-existent working relationships with management and/or other teams.
Each of these issues can result in a maintenance team making an error and failing to

detect it before the aircraft or aircraft system enters service. These errors can result in
operational or maintenance problems (system failures, inappropriate maintenance etc.)
and can even drive additional Human Factors issues in other aviation domains such as the
flight deck or maintenance.
Organisations that are developing UASs must ensure that any maintenance Human
Factors issues (e.g. provision of clear and unambiguous instructions) are addressed. The
means by which this will be achieved must be described to the authority for any proposed
certification project.
2.19. Future Trends
Future developments in UAS are moving more towards mitigating Remote Pilot workload
through advanced decision support systems. Human Factors expertise will be central to
such developments to produce a system that is not only safe but also ensures the correct
level of crew workload for all mission tasks and phases of flight.
 CAP 719 Fundamental Human Factors Concepts
 CAP 716 Aviation Maintenance Human Factors (EASA/JAR145 Approved

Organisations)
 CAP 737 Crew Resource Management (CRM) Training
 CAP 789 Requirements and Guidance Material for Operators
 ISO 9241
 ISO 13407

CAP 722 Chapter 3 | Policy CAA Policy on UAS Autonomy
CAA Policy on UAS Autonomy
3.1. Scope
This guidance relates to the regulatory interpretation of the term “autonomous” and
provides clarification on the use of high authority automated systems in civil UAS.
3.2. Introduction
The dictionary definition of autonomy is “freedom from external control or influence”. The
need to meet the safety requirements, defined in the various Certification Specifications
under CS XX.1309, for "Equipment, Systems and Installations" means that at this point in
time all UAS systems are required to perform deterministically. This means that their
response to any set of inputs must be the result of a pre-designed data evaluation output
activation process. As a result, there are currently no UAS related systems that meet the
definition of autonomous.
In general, UAS systems fall in to two categories:
 Highly automated – those systems that still require inputs from a human operator
(e.g. confirmation of a proposed action) but which can implement the action without
further human interaction once the initial input has been provided.
 High authority automated systems – those systems that can evaluate data, select a
course of action and implement that action without the need for human input. Good
examples of these systems are flight control systems and engine control systems
that are designed to control certain aspects of aircraft behaviour without input from
the flight crew.
The concept of an “autonomous” UAS is a system that will do everything for itself using
high authority automated systems. It will be able to follow the planned route, communicate
with Aircraft Controllers and other airspace users, detect, diagnose and recover from faults
and operate at least as safely as a system with continuous human involvement. In
essence, an autonomous UAS will be equipped with high authority control systems that
can act without input from a human.

3.3. What is the Difference between Automation and Authority?
Automation is the capability of a system to act using a set of pre-designed functions

without human interaction (e.g. robotic manufacturing).
The level of authority a system has is defined by the results that the system can achieve.
For example, a flight control computer may only be able to command a shallow roll angle,
whereas the human flight crew will be able to demand a much higher angle of roll. A full
authority system will be able to achieve the same results as a human operator.
3.4. Use of High Authority Automatic Systems
High authority automatic systems have the capability to take actions based on an
evaluation of a given dataset that represents the current situation including the status of all
the relevant systems, geographical data and environmental data.
Although these systems will take actions based on an evaluation of a given dataset they
are required to be deterministic in that the system must always respond in the same way
to the same set of data. This means that the designs of the associated monitoring and
control systems need to be carefully considered such that the actions related to any given
dataset are appropriate and will not hazard either the aircraft or any third parties in the
same area.
High authority automatic systems are usually composed of a number of sub-systems used
to gather data, evaluate data, select an appropriate set of actions and issue commands to
related control systems. These systems can include flight management systems, detect
and avoid systems, power management systems, etc.
In an UAS a system can have authority over two types of function: general control system
functions (e.g. flight control computers) and navigational commands.
3.5. Delegation to a High Authority Automatic System
The concept of high authority automatic systems covers a range of varying degrees of
system authority ranging from full authority where the systems are capable of operating
without human control or oversight to lesser levels of authority where the system is
dependent upon some degree of human input (e.g. confirmation of proposed actions).
The level of authority a system can have with respect to navigational commands may vary
during any flight, dependent upon the hazards the aircraft is faced with (e.g. terrain or
potential airborne conflict with other aircraft) and the time available for the human operator
to effectively intervene. If the aircraft is flying in clear airspace with no nearby terrain the

system may be designed such that any flight instructions (e.g. amendment to a flight plan)
are instigated by a human operator. However, if the aircraft is faced with an immediate
hazard (terrain/other aircraft) and there is insufficient time for a human operator to
intervene (based on signal latency etc.) the UAS will need to be able to mitigate that risk.
These mitigations may include the use of full authority automatic systems.
Although it is anticipated that most systems will be operated using a lesser level of
authority, the design of the overall system (control station, air vehicle and related
operational procedures) will need to take account of the failure conditions associated with
loss of the command and control communications link between the control station and the
air vehicle and this may drive a need for the use of full authority systems.
3.6. Potential Future Developments
3.6.1. Learning/Self Modifying Systems
A learning, or self-modifying system is one that uses data related to previous actions to
modify its outputs such that their results are closer to a previously defined desired
outcome. Although learning systems do have the potential to be used in UAS, the overall
safety requirements (for example the need to comply with CS XX.1309) still apply. This
means that it may not be possible to use these systems to their full potential.
It is also important to note that these systems have the potential to be more susceptible to
the effects of emergent behaviour and, as such, the evaluation of such systems would out
of necessity need to be very detailed.
3.6.2. Other Potential Developments
It is possible that, at some point in the future, the aviation industry may consider the use of
non-deterministic systems to improve overall system flexibility and performance.
Whilst there are no regulations that specifically prohibit this, the use of non-deterministic
systems will drive a number of system and operational safety assessment issues that will
need to be addressed before the use of this type of technology could be accepted for use
in aviation.
3.7. General

All past and current civil aircraft operations and standards have an inherent assumption
that a competent human is able to intervene and take direct control within a few seconds
at any stage, and that the human will be been presented with enough information to have
continuous situational awareness. It is to be expected that, for the foreseeable future, the
civil aviation authorities would require this human intervention facility to be available for all
UAS regardless of their level of autonomy.
3.8. Human Authority over Autonomous UAS
CAA policy is that all UAS must be under the command of a Remote Pilot. Dependent
upon the level of autonomy, a Remote Pilot may simultaneously assume responsibility for
more than one aircraft, particularly when this can be accomplished safely whilst directing
the activities of one or more other Remote Pilots. However, if this option is to be facilitated
the applicant will need to demonstrate that the associated human factors issues (displayed
information, communication protocols, etc) have been fully considered and mitigated.
3.9. Safe Operation with Other Airspace Users
Autonomous UAS must demonstrate an equivalent level of compliance with the rules and
procedures that apply to manned aircraft. It is expected that this will require the inclusion
of an approved Detect and Avoid capability when UAS are operating outside segregated
airspace.
3.10. Compliance with Air Traffic Management Requirements
Autonomous UAS operation is expected to be transparent to ATM providers and other

airspace users. The autonomous UAS will be required to comply with any valid ATC
instruction or a request for information made by an ATM unit in the same way and within
the same timeframe that the pilot of a manned aircraft would. These instructions may take
a variety of forms and, for example, may be to follow another aircraft or to confirm that
another aircraft is in visual sight.
3.11. Emergencies
The decision-making function(s) of any autonomous UAS must be capable of handling the
same range of exceptional and emergency conditions as manned aircraft, as well as
ensuring that malfunction or loss of the decision-making function(s) itself does not cause a
reduction in safety.

3.12. Factors for Consideration when Applying for Certification of

Autonomous Systems
3.12.1. Data Integrity
Autonomous systems select particular actions based on the data they receive from
sensors related to the aircraft environment (airspeed, altitude, met data etc), system status
indicators (fault flags, etc), navigational data (programmed flight plans, GPS, etc.) and
command and control data received from control stations. As such, UAS developers will
need to ensure that any data related to autonomous control has a sufficient level of
integrity such that the ability to comply with basic safety requirements is maintained. This
will require the development of appropriately robust communication and data validation
systems.
3.12.2. Security
An autonomous system must be demonstrated to be protected from accepting

unauthorised commands, or from being “spoofed” by false or misleading data.
Consequently, UAS will have a high degree of dependence upon secure communications,
even if they are designed to be capable of detecting and rejecting false or misleading
commands. Section 4 covers security issues in more detail.

CAP 722 Chapter 3 | Policy CAA Policy on Security Issues for UAS Operations
CAA Policy on Security Issues for UAS Operations
4.1. Scope
This section offers guidance to industry on how to implement and satisfy the requirements
for security through all UAS lifecycle activities (i.e. initial concept, development, operation
and maintenance and decommissioning). In this context, security refers to the security of
the Unmanned aircraft, including both physical and cyber elements.
4.2. Policy
It is CAA Policy that any UAS operating outside of a UK Danger Area will not increase the
risk to existing airspace users and will not deny airspace to them. This policy requires a
level of safety and security equivalent to that of manned aviation.
A UAS must have adequate security to protect the system from unauthorised modification,
interference, corruption or control/command action.
4.3. Factors for Consideration when Developing Security for UAS
4.3.1. Holistic Approach
When considering security for the UAS it is important to take a holistic approach, paying
equal cognisance to technical, policy and physical security for the UAS as a whole.
Utilising this approach will help ensure that issues are not overlooked that may affect
security and ultimately safety.
By utilising proven industry approaches to the protection of Confidentiality, Integrity and

Availability (CIA), security measures applied can benefit the UAS operator by assuring
availability of service and the integrity and confidentiality of both data and operations.
4.3.2. Security Aspects to be Addressed
Security aspects are required to address particular potential weaknesses to UAS such as
employees, location, accessibility, technology, management structure and governance.
Such security aspects include but are not limited to:

 The availability of system assets, e.g. ensuring that system assets and information
are accessible to authorised personnel or processes without undue delay;
 Physical security of system elements and assets, e.g. ensuring adequate physical
protection is afforded to system assets;
 Procedural security for the secure and safe operation of the system, e.g. ensuring
adequate policies such as Security Operating Procedures are drafted, applied,
reviewed and maintained;
 Data exchange between system elements, e.g. ensuring the confidentiality and
integrity of critical assets is maintained during exchanges within the system, over
communication channels and by other means such as physical media;
 Accuracy and integrity of system assets, e.g. ensuring threats to system assets
caused by inaccuracies in data, misrouting of messages and software/hardware
corruption are minimised, and actual errors are detected;
 Access control to system elements, e.g. ensuring access to system assets is

restricted to persons or processes with the appropriate authority and ’need-to-
know’;
 Authentication and identification to system assets, e.g. ensuring all individuals and
processes requiring access to system assets can be reliably identified and their
authorisation established;
 Accounting of system assets, e.g. ensuring that individual accountability for system
assets is enforced so as to impede and deter any person or process, having gained
access to system assets, from adversely affecting the system availability, integrity
and confidentiality;
 Auditing and Accountability of system assets e.g. ensure that attempted breaches
of security are impeded, and that actual breaches of security are revealed. All such
attempted and actual security incidents must be investigated by dedicated
investigation staff and reports produced;
 Object Reuse of system assets, e.g. ensure that any system resources re-usage,
such as processes, transitory storage areas and areas of disk archive storage,
maintains availability, integrity and confidentiality of assets;
 Asset Retention, e.g. ensuring that system assets are securely retained and stored
whilst maintaining availability, integrity and confidentiality.
Identified and derived requirements would then sit within each identified security aspect
and be applied (where necessary) to parts of the UAS, e.g. ground based system
(including the communications link) and the UA itself. The requirements must be ultimately
traced to the overall policy requirements.

4.3.3. Security Process
Any agreed security design, evaluation and accreditation process will be integrated (where
necessary) with the existing certification, approval and licensing processes utilised for
manned aircraft.
The security design, evaluation and accreditation process will be considered as a factor to
the operational scenario, including but not limited to:
 Applicable flight rules;
 Aircraft capabilities and performance including kinetic energy and lethal area;
 Operating environment (type of airspace, overflown population density);
 Opportunities for attack and desirability.
The operational scenarios, along with other applicable factors, must be combined with
possible weaknesses to the system to determine a measure of perceived risk. A possible
security lifecycle for the UAS is shown in Figure 1 and this particular phase is referred to
as the risk assessment phase of the process.
Risk management techniques must then be utilised to reduce the perceived risk to an
acceptable level of residual risk. As shown in Figure 1 this phase is referred to as the risk
mitigation phase of the process.
The risk management techniques implemented are verified and evaluated for effectiveness
in a regular cycle of ‘action and review’ ensuring optimum effectiveness is maintained
throughout the lifecycle. As shown in Figure 1 this phase is referred to as the validation
and verification phase of the process.
Although the approach above is directly applicable to technical security it must be borne in
mind that this process must be supported by the application of both good physical security
and procedural security and these could be drawn up by interactions between industry, the
CAA and Government agencies.
4.4. Current UAS Security Work
The current security research work draws on sector experience and recognised security
standards. Through liaison with Government agencies, system security policies are formed
that are not only thorough due to their holistic approach but also achievable due to the
recognition that systems will have varying operational roles.

Identify Assets- then, for each asset

Assess business attitude to risk
Assess
Value
Assess Assess Threat Assess Vulnerabilities Develop risk management strategy
Impact of
loss
(Re) assess likelihood of threats being

able to cause undesirable impacts by
exploiting vulnerabilities
Risk Assessment Risk
Strategy
informs
Risk mitigation
Are (residual) risks acceptable No decisions
Yes
Decide how to prioritise risks
Decide how to treat risks
Risk Mitigation Treat risks (apply countermeasures)
Are risk treatments effective? No
Validation and
Verification Yes
Accept residual risks Accreditation Decision
Review criteria
Figure 6 – Security assessment process

CAP 722 Chapter 3 | Policy CAA Policy on UAS Spectrum Issues
CAA Policy on UAS Spectrum Issues
5.1. Scope
This section provides:
 CAA policy on the use of frequencies to support UAS operations;
 Frequencies bands potentially available to support UAS command & control and
detect & avoid systems, their limitations and required authorisation of their use.
5.2. Introduction
The provision of communication, navigation and surveillance is essential to the safe and
expeditious operation of UAS. Whilst there are many existing aeronautical systems that
operate in suitably allocated and protected spectrum that support safety critical
applications, these are often not suitable for UAS operations.
UAS safety critical applications generally do not conform to a flight profile that is consistent
with that assumed for existing aeronautical systems and hence there is a requirement for
the provision of UAS specific systems that will require spectrum support.
However, the identification of suitable spectrum for those UAS safety-critical applications
that cannot be addressed by existing aeronautical systems. In 2012 the allocations in the
frequency band 5 030 – 5 091 MHz were suitably modified to allow for terrestrial and
satellite support for UAS. Additionally, in 2015 some frequency bands were identified that
might be able to provide further satellite support for UAS operations for which studies are
still on-going to identify the conditions under which these frequency bands could be used.
5.3. Aim
The aim of this policy statement is to clarify the position of the CAA in respect to the
spectrum currently available, the limitations on and the application process for its use by
the UAS industry as well as the process for seeking access to alternative spectrum
5.4. Policy
The CAA policy is:

 to ensure that frequencies used to support safety-critical UAS functionality meet

both international and national regulations/legislation;
 to ensure that all frequencies used to support safety-critical UAS functionality have
been co-ordinated and licensed in accordance with the appropriate licensing
regime;
 to ensure that any such licence obtained provides suitable protection to the use of
that frequency appropriate to the functionality and safety criticality of the systems
being supported and the area of operation;
 to assist in the identification of suitable dedicated spectrum to support UAS safety-

critical functionality.
5.5. Radio Regulatory Framework
The International Telecommunication Union (ITU), a sister UN agency to ICAO, is

responsible for the global management of the radio frequency spectrum whose prime
objective is to ensure interference free operation of radiocommunication systems. This is
achieved through the implementation of the Radio Regulations and regional agreements.
Within the UK, management of spectrum is the responsibility of Ofcom.
The availability of spectrum and the licencing regime under which it operates will vary
dependant on the operational requirement (e.g. within or beyond visual line of sight etc),
environment (e.g. urban/rural etc,) and the safety criticality (e.g. separation, kinetic energy
etc) of the function being supported.
5.6. Spectrum Availability
The following frequency bands are appropriately allocated within the Radio Regulations to
support UAS Command & Control and/or Sense & Avoid systems. However, their potential
use to support such systems will be subject to compatibility with incumbent and known
future systems operating or intended to operate in the relevant frequency band.
Frequency Band Potential Protected / Comment

Use Unprotected
255 - 526.5 kHz Detect & Protected Aeronautical use: for Non-Directional Beacons with 0.5
Avoid kHz channelization
Other Information None
34.945 – 35.305 Detect & Unprotected Other Information Power limited to 100 mW, 10 kHz
MHz Avoid channelization
74.8 – 75.2 MHz Detect & Protected Aeronautical use: Marker beacons with a fixed centre
Avoid frequency of 75 MHz
Other Information: None


Use Unprotected
108 – 117.975 MHz Command Protected Aeronautical use: Instrument Land System with 50kHz
& Control channelization, VHF Omni-Ranging with 50 kHz
and/or channelization, Ground Based Augmentation System with
Detect & 25 kHz channelization & VHF Data Link Mode 4 with 25
Avoid kHz channelization.
117.975 – 137 MHz Command Protected Aeronautical use: analogue voice communications with
and 8.33 kHz channelization, VHF Data Link Modes 2 & 4 with
Control 25 kHz channelization
328.6 – 335.4 MHz Detect & Protected Aeronautical use: Instrument Landing System with 150
Avoid kHz channelization.
960 – 1 165 MHz Command Protected Aeronautical use: Distance Measurement Equipment
& Control with 1 MHz channelization, Secondary Surveillance Radar
and/or on 1030 & 1090 MHz, Automated Collision Avoidance
Detect & System on 1030& 1090 MHz, Automatic Dependent
Avoid Surveillance – Broadcast on 1090 MHz and Universal
Access Transceiver on 978 MHz Potential future use for a
new air ground communication system as well as UAS
Command & Control
Other Information: Shared with MoD’s Joint Tactical
Information Distribution System
1 165 – 1 215 MHz Detect & Protected Aeronautical use: Distance Measurement Equipment
Avoid with 1 MHz channelization
Other Information: Planned use by high
precision/integrity Global Navigation Satellite Systems and
shared with MoD’s Joint Tactical Information Distribution
System
1 215 – 1 350 MHz Detect & Protected Aeronautical use: En-route primary radar above 1260
Avoid MHz
Other Information: Global Navigation Satellite Systems
below 1260 MHz
2 400 – 2 500 MHz Command Unprotected Aeronautical use: None
& Control Other Information: Power limited to 100 mW with a
and/or requirement for “listen before talk” or “detect and avoid”
Detect & mitigation and a maximum power spectral density of 10
Avoid mW/MHz
2 700 – 3 100 MHz Detect & Protected Aeronautical use: Airport approach and windfarm
Avoid mitigation radar
4 200 – 4 400 MHz Command Protected Aeronautical use: radio altimeters that sweep across the
& Control whole frequency band and wireless avionic intra-
and/or communication
Detect & Other Information: None
Avoid
5 000 – 5 030 MHz Command Protected Aeronautical use: None currently but is available for
& Control aeronautical satellite communication
and/or Other Information: None
Detect &
Avoid
5 030 – 5 091 MHz Command Protected Aeronautical use: Microwave Landing System at
& Control Heathrow and reserved for co-ordinated use by both
and/or terrestrial/satellite UAS communication systems
Detect & Other Information: None
Avoid


Use Unprotected
5 091 – 5 150 MHz Command Protected Aeronautical use: Aeronautical mobile airport
& Control communication system
and/or Other Information: MoD use for telemetry
Detect &
Avoid
5 150 – 5 250 MHz Detect & Protected Aeronautical use: None
Avoid Other Information: None
5 350 – 5 470 MHz Detect & Protected Aeronautical use: None
5 725 – 5 875 MHz Command Unprotected Aeronautical use: None
& Control Other Information: Power limited to 25mW
and/or
Detect &
Avoid
8 750 – 8 850 MHz Detect & Protected Aeronautical use: none
9 000 – 9 200 MHz Detect & Protected Aeronautical use: Airport surface movement radar
9 300 – 9 500 MHz Detect & Protected Aeronautical use: Airport surface movement radar &
Avoid airborne weather radar
Other Information: Used for maritime radar
13.25 – 13.4 GHz Detect & Protected Aeronautical use: None
15.4 – 15.7 GHz Detect & Protected Aeronautical use: None
66 – 71 GHz Detect & Protected Aeronautical use: None
76 – 81 GHz Detect & Unprotected Aeronautical use: None
Avoid Other Information: Use of the frequency band 76 – 77.5
GHz is restricted to ground use only
95 – 100 GHz Detect & Protected Aeronautical use: None
Table 8 – Spectrum availability
Note: Any proposed use that does not conform to the regulatory limits applicable within a
frequency band will need to be shown to be compatible with incumbent systems and
approved/ licenced by Ofcom.
Applications for the assignment of frequencies within the bands identified or otherwise
must be addressed to OFCOM. Of additional note is that any aircraft system transmitting
on 1030 MHz, as may typically be used in collision warning or sense-and avoid systems,
must not be operated without an approval from the National IFF and SSR Committee
(NISC) (see CAP 761).

5.7. Allocation of Spectrum
The CAA supports OFCOM by providing the UK lead on issues related to aeronautical
spectrum, including UAS. For information on how to participate in the process for the
identification and allocation of spectrum that can be used to support UAS operations
contact the CAA.
Licencing of frequency allocations is the responsibility of Ofcom and hence, where

required, all applications for a frequency assignment should be directed in the first
instance to Ofcom. In frequency bands where the CAA is the assigning authority, then the
application will be passed to the CAA by Ofcom so that the CAA can conduct the technical
work, but Ofcom still remains the licencing authority.
Where a frequency licence is required (e.g. in protected frequency bands or where powers
exceed the current regulatory limits) the CAA will not be able to issue a permission or
exemption.
5.8. Use of 35 MHz, 2.4 GHz and 5.8GHz
There are no specific frequencies allocated for use by UAS in the UK. However, the most
commonly found are 35 MHz, 2.4 GHz and 5.8 GHz.
35 MHz is a frequency designated for Model Aircraft use only, with the assumption that
clubs and individuals will be operating in a known environment to strict channel allocation
rules. It is therefore not considered to be a suitable frequency for UAS operations where
the whereabouts of other users is usually difficult to assess.
2.4 GHz is a licence free band used for car wireless keys, household internet and a wide
range of other applications. Although this is considered to be far more robust to
interference than 35 MHz, operators must act with appropriate caution in areas where it is
expected that there will be a high degree of 2.4 GHz activity.
In addition, operations close to any facility that could cause interference (such as a radar
station) could potentially disrupt communications with the UAS, whatever the frequency in
use.
It is the responsibility of the operator to ensure that the radio spectrum used for the
command and control link and for any payload communications complies with the relevant
Ofcom requirements and that any licenses required for its operation have been obtained. It
is also the responsibility of the operator to ensure that the appropriate aircraft radio licence
has been obtained for any transmitting radio equipment that is installed or carried on the
aircraft, or that is used in connection with the conduct of the flight and that operates in an
aeronautical band.

CAP 722 Chapter 3 | Policy CAA Policy on UAS Registration
CAA Policy on UAS Registration
6.1. Scope
The registration requirements for civil UAS are contained within Regulation (EU)
2018/1139, the EASA Basic Regulation, and in the ANO, and are in line with the
requirements of ICAO Annex 7.
6.2. Policy
The registration requirements for unmanned aircraft differ from those required for other
aircraft in that they are dependent on the category of UAS operation. While some specific
details are still to be clarified, the following basic principles apply:
 UAS operated within the Certified category (i.e. the design is subject to
certification) – each individual UA must be registered
 UAS operated within the Specific category (from 1st July 2020) – the UAS operator
will require to be registered
 Small unmanned aircraft (from 30 November 2019)

– the SUA operator must be registered if the UA has a mass of 250g or more
UA whose design is subject to certification are required to be registered in accordance with

articles 24 to 32 of ANO 2016 unless they are flying under an exemption or under the
provisions of a 'B Conditions' approval issued to an organisation under BCAR A8-9 (see
www.caa.co.uk/cap553). Once the CAA has processed the application, the aircraft will be
issued with a registration ID consisting of five characters starting 'G-' (e.g. G-ABCD) and
the details will be entered into the aircraft register. The registration must be displayed
permanently on the aircraft in accordance with article 32 of ANO 2016.
Operators of UA over 20kg mass that are not subject to design certification (i.e. those
being operated within the Specific category under an exemption) do not currently fall into
any formal registration system, however the process of obtaining the exemption is
currently considered sufficient to satisfy the UAS operator registration requirements. The
requirements will be addressed at a later date, either within EU UAS regulation or within
UK only regulation, as appropriate.
With effect from 30 November 2019, operators of small unmanned aircraft will be required
to be registered in accordance with article 94D of ANO 2016.
EC Regulation 785/2004 requires most operators of aircraft, irrespective of the purposes

CAP 722 Chapter 3 | Policy CAA Policy on UAS Registration
for which they fly, to hold adequate levels of insurance in order to meet their liabilities in
the event of an accident. This EC Regulation specifies amongst other things the minimum
levels of third-party accident and war risk insurance for aircraft operating into, over or
within the EU (including UAS) depending on their MTOM.
Compliance monitoring of the insurance regulation is carried out by the CAA Aircraft
Registration Section. Details of the insurance requirements can be found on the CAA
website 11 under “Mandatory Insurance Requirements”.
Air Navigation Order 2016, articles 24 to 32 and 94D.
Other guidance material is available at www.caa.co.uk/aircraftregister .
11 www.caa.co.uk/default.aspx?catid=122&pagetype=90&pageid=4510

CAP 722 Chapter 3 | Policy CAA Policy on Radar Surveillance
CAA Policy on Radar Surveillance
7.1. Scope
There have been no previous CAA regulations governing the surveillance requirements for
civil registered UAS in UK airspace. All civil aircraft fly subject to the legislation of the
ANO. However, in accordance with its powers under Article 266 of the ANO 2016, the CAA
may exempt UAS operators from the provisions of the ANO and the Rules of the Air,
dependent upon the aircraft’s potential to inflict damage and injury. This policy is
applicable to all civil UAS operating within the UK Flight Information Region (FIR) and
Upper Flight Information Region (UIR), regardless of origin.
7.2. Policy
This surveillance policy is complementary to the Detect and Avoid guidance contained in
Chapter 3, Section 1. In broad terms, UAS must be able to interact with all other airspace
users, regardless of the airspace or aircraft’s flight profile, in a manner that is transparent
to all other airspace users and Air Navigation Service Providers (ANSPs), when compared
to manned aircraft. Unmanned aircraft must be interoperable with all surveillance systems
without any additional workload for ATCOs, surveillance systems, manned aircraft pilots or
other Remote Pilots. UAS must carry suitable equipment so as to be interoperable with
aircraft equipped with mandated Airborne Collision Avoidance System (ACAS) such as
TCAS II. It must be noted that, where a UAS employs a collision avoidance system with
reactive logic, any manoeuvre resulting from a perceived threat from another aircraft must
not reduce the effectiveness of a TCAS II resolution advisory manoeuvre from that aircraft.
It is recognised that the Radar Cross Section (RCS) and size of certain categories of
aircraft will make detection by non-cooperative 12 surveillance systems difficult, especially
at low-level. Consequently, cooperative ground and/or air-based surveillance systems 13
are traditionally deployed by ANSPs to complement coverage of non-cooperative systems,
especially in controlled airspace.
The primary means of cooperative surveillance within the UK is SSR Mode Select
Elementary Surveillance (Mode S ELS). However, within certain areas of UK airspace, the
carriage of an SSR transponder is not mandatory (see UK AIP Gen 1.5). In such airspace,
where an Air Traffic Radar service is not mandatory, non-transponder equipped aircraft will
12 Primary Surveillance Radar (PSR).

13 Secondary Surveillance Radar (SSR).

not be 'visible' to ACAS. Consequently, in these areas 'see and avoid' is often the primary
means of separation of aircraft. Until it is possible to equip unmanned aircraft with ‘Detect
and Avoid’ capabilities 14 that comply with appropriate future requirements and the SSR
carriage policy for Unmanned Aircraft can be reviewed, any Unmanned Aircraft operating
outside visual line of sight in non-segregated airspace must be equipped with a functioning
SSR Mode S transponder, unless operating within the terms of an exemption from this
requirement.
Electronic Conspicuity (EC) devices offer an alternative, low cost option for cooperative
airborne surveillance that can effectively signal an aircraft’s presence to other similarly
equipped airspace users, thereby enhancing situational awareness for those users. EC
has been available to certain General Aviation users since 2016 and some UAS operators
also employ it where appropriate. EC devices can also alert pilots to the presence of other
aircraft, which assists General Aviation pilots in the visual acquisition of those aircraft and
allow avoiding action to be taken as necessary. Similarly, EC may assist remote pilots in
remaining clear of other aircraft when operating beyond visual line of sight. EC devices
use ADS-B transmitters and receivers and it must be recognised that these have certain
technical limitations and are not interoperable with transponders or ACAS. They offer
limited ground surveillance capability at present but may be ideally suited to areas with
multilateration radar coverage. ADS-B receivers can be a valuable tool for UAS operators
since they have the potential to receive transmissions from surveillance systems of all
aircraft, thereby providing enhanced situational awareness.
EC devices are becoming increasingly available to UAS operators and manufacturers offer
the ability to integrate them with an unmanned aircraft using software development kits
(SDKs) and application programmable interfaces (APIs) that provide control and display
capability at the remote pilot’s station. UAS operators should be aware that they must
observe certain obligations prior to and when using EC devices, which are as follows:
- the EC device must have an equipment approval acceptable to the CAA;
- the operator must obtain an Aircraft Address and programme it into the device;
- the operator must obtain an aircraft radio licence from Ofcom.
Full details on these aspects and acquiring and using EC devices can be found in CAP
1391 Electronic conspicuity devices.
14 Described in Chapter 2, Section 2.

 UK AIP GEN 1.5
 ANO 2016
 ICAO Annex 10 SARPs
 CAP 1391

CHAPTER 4 | Certification & Airworthiness
CAP 722 Chapter 4 | Certification and Airworthiness Certification
Certification
1.1. Scope
This chapter offers guidance to industry on what aircraft certification is and how the
activities associated with aircraft certification interrelate with the activities associated with
continuing and continued airworthiness.
1.2. Lead Agency
Within Europe the regulatory framework is defined by the European Commission (EC) and
enacted by the European Aviation Safety Agency (EASA) and National Airworthiness
Authorities (NAA). The regulatory framework responsibilities are therefore shared
between EASA and NAAs and address:
 Initial Airworthiness (certification and production)
 Continued and Continuing Airworthiness
 Operations
 Air Traffic Management
The regulatory framework and sharing of roles and responsibilities is described within the
EASA Basic Regulation (Commission Regulations 2018/1139). EASA is the primary
agency for all rulemaking activities and conducting initial and continued airworthiness
aspects.
It must be noted that within the Basic Regulation certain aircraft categories are currently
defined to be outside of scope and hence these aircraft remain subject to national
regulation. This applies to aircraft carrying out military, customs, police, search and
rescue, firefighting, coastguard or similar activities or services (State aircraft).
A number of exceptions to this are also defined – these are commonly referred to as
Annex I aircraft. These are defined within Annex I of the EASA Basic Regulation.
1.3. Policy
The following text provides an overview of the objectives of the airworthiness and
certification processes and is intended to give a general understanding of the various
aspects of civil certification and the related organisational oversight activities. It is not a

complete or detailed explanation of this complex subject.
The principles outlined in this Chapter apply only to Certified UAS platforms.
1.4. Certification Objectives
Under the International Civil Aviation Organisation (ICAO) and the Convention on
International Civil Aviation (commonly referred to as the “Chicago Convention” (ICAO Doc.
7300. Annex 8 contains the SARPS for Airworthiness)) there is a system of internationally
agreed standards and recommended practices by which each contracting state can
establish a means to ensure a minimum level of safety is established and achieved, thus
enabling mutual recognition of individual aircraft operating within each other's airspace.
As not all types of aviation require routine international operating capability, each state can
define and establish their own standards and practices for these national activities. Within
Europe this has, for most aircraft types, been harmonised across states through the EU
Commission and the EASA, as described above.
Therefore, it is important to recognise that the headline title of airworthiness/certification is

a means by which an NAA can establish and attest to compliance with an agreed set of
standards. These standards cover the necessary range of aircraft types and the activities
to be undertaken; typically, the standards applied can be, and usually are, different for
varying classes of aircraft and their intended use. For example:
 To comply with the ICAO international requirements aircraft must be operated under
cover of an Operational Approval; each aircraft must have a valid Certificate of
Airworthiness (which is underpinned by an approved Type Design) and be flown by
appropriately qualified and licensed flight crew.
At the other end of manned aviation small personal use (recreational) aircraft may have a
Permit to Fly, which as a National approval, limits use to that country and could include
limitations and conditions on where and when it can be flown (e.g. class of airspace,
weather conditions, etc). It must also be noted that a National approval is just that, so
precludes automatic rights of use/operation in another country; this does not prevent use
or operation in another country, but it does mean each NAA will need to determine how
and what it will allow by separate process.
Thus, certification is a process by which the capability and operational limits of an aircraft
are determined.

1.5. Initial, Continuing and Continued Airworthiness
Within the certification and airworthiness system there are three basic processes to set
and maintain required standards. These processes determine and maintain the intended
level of safety:
 Initial airworthiness processes;
 Continuing airworthiness processes;
 Continued airworthiness processes.
The initial airworthiness processes are those used to determine the applicable
requirements and establish that an aircraft design is demonstrated to be able to meet
these requirements. This includes the safety targets and the development of instructions
for use and ongoing care/maintenance. Within the EASA framework, which is adopted in
the UK, it would also cover the elements of production, i.e. those aspects of taking the
approved design and manufacturing the end product to the point of a useable aircraft. This
phase is therefore complete prior to an aircraft entering into service.
The continuing airworthiness process refers to the system of management of the aircraft
and the scheduling and actioning of ongoing preventative and corrective maintenance to
confirm correct functioning and to achieve safe, reliable and cost-effective operation.
Continued airworthiness refers to the monitoring, reporting and corrective action processes
used for in-service aircraft to assure they maintain the appropriate safety standard defined
during the initial airworthiness processes throughout their operational life.
In parallel with each of these processes, there are schemes that require or provide for
organisation approvals, e.g. design, production, maintenance and organisation approvals.
These approvals enable the NAAs to recognise capability within a company system; this
limits the level of investigation and oversight that may be necessary to establish
compliance against the regulatory standards applicable to individual products.
1.6. Initial Airworthiness Processes
The initial airworthiness process is intended to establish a desired level of airworthiness

integrity for an aircraft and to demonstrate that this level of integrity can be achieved. In
this case, integrity can be taken to include all aspects of the design (structurally and
systemically) to cover safety, reliability, availability, capability, etc. When the desired level
of airworthiness integrity is met and consistently shown to be achieved, the aircraft can be
considered to provide an acceptable level of safety; this covers both the vehicle (and any
person(s) on board, if applicable) and, by inference from continued safe flight, to persons
and property on the ground.

The initial airworthiness processes have the following basic elements for design and
production:
 Establishment of the design/certification requirements (certification

specifications) which define the high-level design criteria and showing that
these are met.
 The design organisation aspects which covers the capability and competence
of the company for the design of the complete aircraft, systems or individual
parts.
 The production organisation aspects which cover the capability and

competence for the manufacture and assembly of the complete aircraft,
systems or individual parts in accordance with the approved design and
testing of the aircraft prior to delivery.
The design organisation is charged with demonstrating to the certification authority that the
proposed design is compliant with the established and agreed certification specifications or
other requirements. Similarly, the production organisation is responsible to show the end
product is in conformance to the design.
For current categories of manned aircraft there are already established design/certification
requirements, such as the EASA Certification Specifications (e.g. Large Aeroplanes (CS-
25), Large Rotorcraft (CS-29), Very Light Aircraft (CS-VLA), and Very Light Rotorcraft (CS-
VLR)). These also provide guidance material on the intent of the requirement and methods
of showing compliance that have been found to be acceptable. However, it is recognised
that these do not fully address the range of aircraft potentially possible, how the
technology elements pertinent to UAS may cross the boundaries between the categories
of the requirements.
Except for the very smallest aircraft, where the safety aspect is controlled by separation
and operational management, each class of aircraft will have some level of safety
requirement. At the highest end, where a formal certification approval is necessary, this
safety assessment requirement for "Equipment, Systems and Installations" and the
associated guidance material is already defined in the Certification Specifications under
paragraph CSXX.1309. However, once again this may not be wholly appropriate for all
categories of aircraft.
1.7. Continuing airworthiness processes
The continuing airworthiness processes are intended to assure that in–service aircraft are
managed and maintained and that these actions are performed correctly, by appropriately
capable persons, in accordance with the instructions developed by the design organisation
so that assumptions and considerations made during the design, particularly in respect of
safety, remain valid. As a result, these processes also need effective communication

between the operator, maintenance organisations and the design organisations to ensure
that necessary information is shared and if necessary corrective actions taken.
The continuing airworthiness process will support any modifications, repair or component
replacement once an aircraft has entered service. This is achieved by not only
undertaking the incorporation of the changes, but also in the management of configuration
records, updating of maintenance instructions, etc.
1.8. Continued airworthiness processes
The continued airworthiness processes are intended to provide a closed loop monitor and
corrective action cycle for in-service aircraft to assure that the intended level of safety is
maintained. The process starts with activity within the certification work (for example the
development of the maintenance schedules and instructions on how to perform this
activity). Thereafter, it includes the monitoring of experience of in-service aircraft and,
when necessary, the definition and promulgation of corrective action instructions.
The development of maintenance schedules typically considers and uses information from
the aircraft design and safety assessment processes to determine what maintenance
activities are required and how frequently they will be performed to maintain the
appropriate level of aircraft integrity (for example replacing parts before they would
typically wear out or fail will prevent the consequence of this and hence aid both safety
and commercial costs).
The monitoring and reporting processes support the collection and analysis of in-service
information and enable the design organisation to be satisfied that the overall level of
safety is being achieved, or if necessary, to determine and promulgate corrective actions
to address problem areas.
If these programmes are run correctly, they have the potential to save organisations
money – it is usually cheaper in terms of both money and time to fix a minor problem
before it becomes a serious problem.

CAP 722 Chapter 4 | Certification and Airworthiness General Certification Requirements
General Certification Requirements
2.1. Scope
This section offers guidance on the general certification requirements for UAS, where this
is applicable.
2.2. Policy
The approach taken by CAA for certification is, in principle, the same as that followed by
EASA and is described below. Within this process, the actual requirements that make up
the certification basis, which must be shown to be met, may well be different for each NAA
due to the views, experience and concerns of each country.
2.3. Applicability
UAS ‘whose design is subject to certification’ i.e. aircraft that meet the conditions specified
in Regulation (EU) 2018/1139 (the Basic Regulation) – Annex IX, need to be certificated
by EASA and hence reference to them must be made.
2.4. Certification Process
The initial airworthiness or “Type Certification” process can be considered to follow a

simple flowline, albeit there may be parallel paths in obtaining Design Organisation
Approval (DOA) and Production Organisation Approval (POA), where these are necessary,
which must come together at key cross-contact points.
The following describes the typical process for aircraft.
 Phase 0: Company develops idea to point of maturity where certification is considered

appropriate or necessary. During this phase the company will need to consider both
functional requirements (to derive a product that is capable of performing what is
intended) and also the external requirements that may need to be met (certification,
operational, legislative, environmental etc.). It may also include the building and testing
of initial developmental and prototype machines.
 Phase 1: Application is made to the competent authority for design to begin the
certification process. At this point the formal process begins which enables two things:

 The applicable certification requirements are defined as those published at this

date. Compliance with these requirements must be demonstrated within five
years. If this is not achieved, later published revisions to the requirements may
be introduced.
 The initial or general familiarisation of the product begins, this enables the
competent authority for design to begin to review the applicable specific
requirements set and notify/confirm this to the company and to determine the
technical areas that will require specialist involvement in the project.
 Phase 2: Detail or technical familiarisation leading to the agreement of the certification

requirements set – the certification basis. In this phase the company briefs the
competent authority for design specialists on the detailed design, the requirements
that they have considered applicable and how these are planned to be demonstrated
as being met – the means or method of compliance. The competent authority for
design specialist team considers these proposals and, following further discussion with
the applicant, an agreed certification basis is documented. This basis will usually start
from one (or more) of the existing Certification Specifications from which unnecessary
items will be deleted. Additions may be introduced to cover where the requirement is
inadequate or there are no suitable requirements due to the new or novel technologies
used. For simple designs these phases can be covered as one.
 Phase 3: The Company works to demonstrate compliance with the Certification Basis
in the agreed way. If necessary further dialogue is held to ensure that the most
effective ways of working are used to agree changes in the means/methods of
compliance, or indeed to revise the requirements if changes to the original design are
made and warrant this.
 Phase 4: Compliance has been shown. The competent authority for design team will
complete their report and recommend issuance of the aircraft type design approval,
which is recorded by the Type Certificate (TC) and the associated Type Certificate
Data Sheet (TCDS). These define the aircraft type, high level features, the certification
basis met, applicable maintenance, inspection and operational instructions, key
limitations, restrictions and conditions and other necessary information that form the
approved design.
The current CAA policy is not to mandate airworthiness certification as outlined above but
to make use of the UAS Operating Safety Case process. However, it is considered worth
noting that elements of the safety case must reflect similar information to that which would
be developed within the certification process. It is therefore considered that a level of
understanding of the certification requirements may therefore be useful, and maybe
beneficial in designing the aircraft, even though not required by the regulatory system.

2.5. Certification Basis
From the above processes the derivation of the applicable requirements is clearly a key
aspect. However, it is clear that the current requirements set do not align with the
types/size/mass of aircraft that are being developed as UAS.
Unfortunately, the timeline for developing requirements is likely always to be behind the
rate of technological advancement. The current approach is therefore to identify the
category that fits as best as possible to the type/classification of the aircraft – and subtract
what is not necessary and add to fill the gaps where required. The gaps can be filled by
parts of other requirement sets, where practicable, and/or by developing new material
where necessary.
 For example: a simple fixed wing aeroplane design may align well with the VLA
(Very Light Aeroplanes) category with respect to structure and control surface
actuation etc. However, because of the remote pilot aspects, the design may have a
sophisticated command and flight control system, which is not addressed in CS-
VLA. Use of the relevant sections of CS-23 or even CS-25 may be applicable.
The main difficulty with this approach, apart from the commercial risk prior to agreement
with the competent authority for design, is the potential lack of cohesion between the
safety target levels from the different standards.
2.6. Interrelationship between the Three Stages of Airworthiness

Oversight
2.6.1. Initial and Continued Airworthiness
During the initial certification of an aircraft the initial and continued airworthiness processes
may be considered to run concurrently, as the information developed within the initial
airworthiness processes feeds into the continued airworthiness processes to develop the
“instructions for continued airworthiness”, i.e. the maintenance schedules and tasks which
need to reflect the assumptions and considerations of use of the aircraft.
In principle, the intent is that once it has been demonstrated both the initial airworthiness
and continued airworthiness requirements have been met, an aircraft type will be issued
with a Type Certificate.

Type Certificates are only issued to the following:
 Aircraft
 Engines
 APUs
 Propellers
The development of all other types of aircraft system is required to be overseen by the
Type Certificate applicant.
Once an aircraft, engine, APU or propeller holds a Type Certificate any changes will fall in
to the following categories:
 Major Change – This is a significant change to the design of an aircraft, engine,

propeller or related system that is designed and implemented by the holder of the
Type Certificate.
 Supplemental Type Certificate – This is a significant change to the design of an

aircraft, engine or propeller that is not designed and implemented by the holder of the
relevant Type Certificate.
 Minor Change – This is a non-significant change to the design of an aircraft, engine,

propeller or related system which is not permitted to affect the extant aircraft, engine or
propeller level safety assumptions.
 Change in Operational Use – This is a change to the operational use of an aircraft,

engine or propeller that falls outside the agreed scope of use defined during the initial
and continued airworthiness processes. In principle this must be discussed and
agreed with the relevant TC holder, but this is not actually mandated.
Clearly any change to a certificated system that does not involve the TC holder has
potential implications for aviation safety.
2.6.2. Continuing Airworthiness
The continuing airworthiness process begins with an evaluation of an organisation to

determine whether or not it meets the basic requirements to be allowed to perform initial
and/or continued airworthiness functions.
This process seeks to determine compliance against one or more of a number of

organisational approval requirements documents:
 Part 21 – “Certification of Aircraft and Related Products, Parts and Appliances, and of
Design and Production Organisation”. In simple terms this document applies to
organisations involved in initial airworthiness.

 Part M – “Continuing Airworthiness Requirements”. This relates to organisations that

are responsible for managing and overseeing maintenance tasks and maintenance
scheduling.
 Part 145 – “Approved Maintenance Organisations”. This applies to organisations that

perform continued airworthiness related tasks under the management of an
organisation approved to Part M.
 Part 147 – “Maintenance Training Organisational Approvals”. This applies to

organisations that are responsible for the provision of aviation related training.
 Part 66 – “Certifying Staff”. This documents the competency requirements for

personnel that are responsible for signing off aircraft or aircraft systems as
serviceable.
Further information on these regulations and requirements may be found on the EASA
website: https://www.easa.europa.eu/regulations
No organisation is permitted to work within the aviation industry unless they either have
the relevant approvals, as dictated by the continuing airworthiness processes or they are
overseen by an organisation that holds the relevant approval. This is intended to ensure
that any aviation work is performed with a degree of integrity commensurate to the risk
associated with that activity. Once an approval has been granted, the continuing
airworthiness process runs concurrently with the initial and continued airworthiness
processes to ensure that an appropriate level of organisational integrity is maintained to
support the individual project/aircraft level tasks overseen by the initial and continued
airworthiness processes.
If the initial and/or continued airworthiness processes identify organisational risks, this
information is passed back in to the continuing airworthiness processes to ensure that
these risks are managed appropriately.

CAP 722 Chapter 4 | Certification and Airworthiness What Level of Certification Do I Need?
What Level of Certification Do I Need?
3.1. Scope
This section offers guidance to industry on the level of certification required for each UAS
type. Where no formal airworthiness certification is required guidance is given on the
approach to take.
3.2. Policy
The level of certification required for an aircraft or UAS is based upon the intended use.
As described in section 2 of this chapter, at the highest level there are aircraft that have a
Certificate of Airworthiness underpinned by Type Certification, continued and continuing
airworthiness processes and design and production organisation approvals. These aircraft
are flown by rated and licensed pilots under the procedures of an approved operator and
thus are capable for international operations under the mutual recognition arrangements
from ICAO and the International Convention.
At the opposite end of the spectrum, we have aircraft that are not required to hold any
airworthiness approvals but can be operated commercially under cover of an operating
permission provided they are suitably separated from third parties and property.
Compliance with the most demanding requirements provides for a widest range of
operational privileges, whereas a lack of demonstrable airworthiness can still be
accommodated – but with significant restrictions on the operations where appropriate.
This approach is intended to provide a reasonable and proportionate level of regulation.

This is based on the scale and level of risk each category of aircraft and its use could pose
to both the general public and their property, whether on the ground or in an aircraft. The
challenge therefore is to match the operational aspirations, and the risk this could pose,
with proportionate airworthiness requirements that provide adequate management of this
risk.
3.3. Aircraft Classification
The current framework established and used by the CAA, and other NAAs, classifies
aircraft based on simple discriminates or type (e.g. balloon, fixed or rotary wing) and mass.
This reflects the historic developments in manned aviation – but is not necessarily fully

CAP 722 Chapter 4 | Certification and Airworthiness What Level of Certification Do I Need?
appropriate for UAS. However, until such time as alternative classification protocols are
agreed this system is in place. Working within this means we have very simple
categorisations.
UAS fall within the remit of the EASA Basic Regulation 2018/ 1139 Annex IX, unless they
are State aircraft or fall within the exceptions defined in Annex I.
https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32018R1139&from=EN

CAP 722 Chapter 4 | Certification and Airworthiness General Safety Assessment Points
General Safety Assessment Points
4.1. Scope
This section offers guidance on some general safety assessment issues for UAS
Certification.
4.2. Policy
The intent of a Safety Assessment is to demonstrate that the aircraft is safe enough for the
manner and type of operation it is intended to perform. It is not intended here to describe
any of the many different types of assessment or analyses that can be undertaken, but to
outline the basic aspects to be considered.
It is important however to recognise that Safety Assessments, if conducted as a

fundamental and iterative design process, can provide benefits in terms of the level of
safety achievable. This also achieves a degree of reliability or availability possible and
even minimise the cost of ownership through effective maintenance schedules.
If the Safety Assessment is considered simply as a retrospective analysis the result can
only reflect the frozen design. Whilst this could be sufficient, it does also carry the risk that
any shortfall can only be addressed by redesign or by limitations or restrictions on the use
- which could be significant enough to preclude viable operation.
4.3. Assessment Steps
A Safety Assessment may be considered in simple steps:
 Determination of the set of aircraft level threats/hazards related to functional failures

are identified;
 The severity of the consequence for each of these failure conditions is

determined/classified;
 This classification could be different for differing scenarios, e.g. during different phases
of flight;
 The target level of safety (TLOS) is assigned for each failure condition;
 The systems and component failures that could contribute to each of these failure
conditions is assessed or analysed to establish if the individual TLOS is met;

 Compliance with each individual failure condition and the overall aircraft level target is
shown.
Within the airworthiness requirements set, as discussed below, the large aircraft
certification specifications contain specific requirements and levels of safety defined in
probability terms. For smaller classes of aircraft, the airworthiness requirements may not
define levels of safety to this detail – hence the method of demonstrating compliance is
open for discussion and may be able to be based on judgement and justified arguments
rather than detailed probabilistic analysis. This is clearly important as with lower levels of
robust component reliability data the more challenging is the task of developing probability
analyses.
4.4. Safety Assessment Considerations
Each of the UAS design requirement sets will include system safety requirements. These
are often referred to by the applicable paragraph number of CS-XX.1309. This requires
that the probability of a failure is inversely proportional to the severity of its effect at aircraft
level, i.e. high criticality systems are required to have an extremely low probability of
failure.
These certification requirements were established many years ago based on in-service
experience (accident data etc) and a desire to set a standard that would drive
improvements in what was then being achieved. For each class of passenger transport
aircraft (large and small fixed wing aircraft, rotorcraft, etc.), an acceptable fatal accident
rate was defined, e.g. 1 accident in 10 million flight hours (10-7 per flight hour), for a large
fixed wing aircraft.
Then based on simple assumptions regarding the number of aircraft systems and
potentially critical failures in each of these, a target level of safety was defined for each
critical failure. This is described in detail within the advisory material that goes with the
requirement.
The validity of using these probability targets for UAS is currently a debated subject.
Clearly, they relate to passenger transport aircraft and the safety of passengers carried.
However, it must be noted that by protecting persons on board an aircraft, third parties on
the ground will also be protected.
There is also some discussion that the types of operation undertaken by passenger aircraft
are quite different to the range of operations undertaken by UAS, hence once again the
probability targets are inappropriate. In respect to this, it must be noted that the safety
assessment process already accounts for this to some extent, as due to these differences
the consequence or severity of effect could be quite different thus giving a different target
level of safety.

For UAS, the safety assessment and any analysis or justification to demonstrate
compliance with the level of safety target is primarily based on the aircraft system and its
associated failure mechanisms. The aircraft system is the total system required for safe
flight and landing, e.g. the aircraft, control station, command and control datalinks and any
launch or landing/recovery systems.
In principle, it does not place reliance on external factors that may mitigate the failure –
these are the safety nets that could prevent the worst-case scenario.
It must also be noted that where the simple assumptions made in the certification safety
assessment requirements are not valid, e.g. independent versus integrated systems,
simple versus complex and the number of critical failure conditions, it may be necessary to
impose more stringent targets to individual failure conditions in order to meet the aircraft
target level of safety.
For UAS the proportionate approach taken does not require a safety assessment to the
level described above. However, the safety case approach does still require consideration
of the hazards (including those that could be due to aircraft system failures), their severity,
and justification of how these will be mitigated and managed. It is therefore envisaged that
some level of assessment and justification of how and why hazards are suitably managed
will be necessary, albeit not to the level that uses detail probability-based analyses.
4.5. Other Considerations
The value of the safety assessment process in the development of maintenance

programmes, e.g. the type and frequency of maintenance actions, must also be
recognised. The outputs of the processes provide useful data to determine what
maintenance activities are required and how frequently they will be performed to maintain
the appropriate level of aircraft integrity. These maintenance actions can prevent critical
failures, e.g. by replacing items before they are likely to fail, or by detecting problems
before operation of the aircraft. Not only does this support safety but it has the potential to
save money – it is usually cheaper in terms of both money and time to fix a minor problem
before it becomes a serious problem.

CHAPTER 5 | Operations
CAP 722 Chapter 5 | Operations Airspace Principles
Airspace Principles
1.1. Introduction
The purpose of this chapter is to outline the policies, constraints and regulations that are to
be adhered to when conducting UAS operations within UK airspace.
The legal constraints on flying operations, including UAS, within UK airspace are
contained within the ANO and it must be noted that the use of Danger Areas (DAs) for the
segregation of RPAS activities might be subject to specific regulations pertinent to the
DA 15. Information on airspace regulation within DAs must therefore be sought from the
relevant DA authority. SARG Airspace Regulation will assist in identifying the appropriate
authority if required.
Whilst the segregation of UAS from other airspace users provides a safe operating
environment, the process for establishing such airspace reduces the flexibility of operation
sought by the user community. This chapter does not cover reactions to
unplanned/emergency situations, as these are already catered for by the use of Restricted
Area (Temporary) (RA(T)) and Emergency Restriction of Flying (ERF) procedures.
1.2. Scope
The guidance below details the operating principles associated with UAS flights both in
segregated and non-segregated airspace. Specific guidance for model aircraft is detailed
in CAP 658, Model Aircraft: A Guide to Safe Flying.
1.3. Policy
Regulation (EC) 2018/1139 (the EASA Basic Regulation) applies to all unmanned aircraft,
other than certain types of tethered aircraft. However, at present, the European
Commission Implementing Regulations associated with UAS operations are not yet
applicable (applicability date will be 1st July 2020). Therefore, until these Implementing
Regulations become applicable, the national legislation laid out in the ANO will still apply.
There is no lower weight limit below which the ANO does not apply; however, the extent to
which the regulations apply depends upon the mass of the aircraft. ANO 2016 articles 94,
15
This includes, but is not limited to, instructions laid down in SARG Policy Statements regarding Danger Areas
and Special Use Airspace Safety Buffer.

94A to G and 95 define constraints that are unique to small unmanned aircraft and small
unmanned surveillance aircraft. Some of these constraints are dependent on how, or
where, the aircraft is used. ANO 2016 article 241 applies to all weight categories and
stipulates that any person must not recklessly or negligently cause or permit an aircraft
(manned or unmanned) to endanger any person or property (which includes other aircraft
and their occupants). If the CAA believes that danger may be caused, then the CAA may
direct that the aircraft must not be flown (ANO 2016 article 257 - CAA’s power to prevent
aircraft flying).
1.4. Airspace Principles for UAS Operations in the UK
UK aviation legislation is designed to enable the safe and efficient operation of all aircraft
in all classes of airspace. UAS operators must work within this same regulatory framework.
UAS do not have an automatic right to airspace if safety provision cannot be made or if
such operations would have an unreasonably negative impact on other airspace users. In
order to integrate with other airspace users, UAS operators must ensure that their aircraft
can demonstrate an equivalent level of compliance with the rules and procedures that
apply to manned aircraft.
Until UAS can comply with the requirements for flight in non-segregated airspace, one-off
or occasional BVLOS UAS flights outside permanently established segregated airspace
(I.e. DAs) may be accommodated through the establishment of Temporary Danger Areas
(TDAs). TDAs must not be considered to be a convenient ‘catch all’ for short notice UAS
activities that can simply be requested, and implemented, without due consideration for
other airspace users. TDAs will mainly be used for longer term measures, where activities
have been properly planned and prepared, and adequate time is available for full
consideration by SARG Airspace Regulation along with full promulgation. TDAs are
covered more fully below.
Unless special provision is made with the Air Traffic Service Unit (ATSU) handling the UAS
activity, the provision of an Air Traffic Service (ATS) to an unmanned aircraft must be
transparent to the controller. In other words, the controller must not have to do anything
different using radiotelephony or landlines than he or she would for other aircraft under his
or her control, nor must the controller have to apply different rules or work to different
criteria. The following points are of note:
 UAS must be able to comply with instructions from the ATS provider and with
equipment requirements applicable to the class of airspace within which they intend to
operate. ATS instructions must also be complied with in a timescale comparable with
that of a manned aircraft.

 All UAS callsigns must include the word "UNMANNED", on first contact with the ATS
provider, to ensure that air traffic controllers are fully aware that they are dealing with a
UAS flight.
 If “special provisions” are made with the associated ATSU, it is essential that these do
not reduce the situational awareness of other airspace users.
1.5. General Principles for UAS Operations within Segregated

Airspace
Unless able to comply with the current requirements of the ANO, including the Rules of the
Air, UAS flights which are operated beyond the visual line of sight of the remote pilot are
required to be contained within segregated airspace. The UK uses DAs as the primary
method of airspace segregation for UAS operations.
For flights within segregated airspace, whilst some restrictions may still apply, an
unmanned aircraft will generally be given freedom of operation within the bounds of the
allocated airspace, subject to any agreed procedures and safety requirements. An
authorisation to operate will take into account the risks associated with any unintended
excursion from the allocated airspace and it will also consider the possibility of airspace
infringements. In addition, measures that may be put in place to enhance the safety of
UAS activities will also be considered in the authorisation process.
While segregated airspace, by its nature, provides exclusive use of that airspace to the
UAS activity, boundaries are not impervious to aircraft infringements. In order to enhance
the safety of UAS operations, the following constraints may be imposed:
 Where available, the remote pilot is to make use of an ATS provider to monitor UAS
flights and to provide a service to them and to other aircraft operating in the vicinity of
the segregated airspace;
 Communications are to be maintained between the ATS provider and the remote pilot;
 Procedures are to be put in place for, amongst others, emergency recovery, loss of
control link and the avoidance of infringing aircraft.
1.6. General Principles for UAS Operations in Non-Segregated

Airspace
For all flights being conducted in airspace that is not segregated, the aircraft performance
and all communications with the ATS provider must be continuously monitored by its
remote pilot. To comply with ATS instructions in a timescale comparable with that of a
manned aircraft, it is imperative that the remote pilot is capable of taking immediate active

control of the aircraft at all times.
Special equipment (e.g. Secondary Surveillance Radar (SSR) Transponder) mandated for
manned aircraft in certain classifications of airspace 16 must also be considered a minimum
requirement for UAS intending to fly in the same airspace.
An approved method of assuring terrain clearance is also required.
Standard Operating Procedures are required, and these would normally be contained
within an organisation’s UAS Operations Manual. As a minimum, the following procedures
must be covered:
 Take-off and landing procedures;
 En-route procedures;
 Loss of control data link; and
 Abort procedures following critical system failure.
UAS must be able to comply with the Instrument or Visual Flight Rules (IFR or VFR) as
appropriate to the class of airspace and the weather conditions
Additional safety requirements that will be considered under permissions and exemptions
may include that the aircraft must not be flown:
 Unless it is equipped with a mechanism that will cause the aircraft to land in the event
of disruption to or a failure of any of its control systems, including the radio link, and
the remote pilot has satisfied himself that such mechanism is in working order before
the aircraft commences its flight;
 Unless the remote pilot has reasonably satisfied himself that any load carried by the
aircraft is properly secured, that the aircraft is in an airworthy condition and that the
flight can safely be made. Operators and manufacturers who are in any doubt as to the
airworthiness of their system must seek independent assessment from either the CAA
or an appropriate CAA-approved qualified entity.
1.7. Detect and Avoid
In order to maintain the appropriate levels of safety, a suitable method of aerial collision
avoidance is required for all UAS operations. Because of this, UAS operations will not
normally be permitted within non-segregated airspace, beyond the direct unaided visual
line-of-sight of the remote pilot, without an acceptable DAA capability.
Note: The use of 'First Person View R/C' equipment (see CAP 658) is not considered to be
16
For example, flight above 10,000 ft within Class G airspace or flight within a Transponder Mandatory Zone.

acceptable for use as a DAA solution.
The minimum DAA requirements for routine BVLOS UAS operations to be conducted
within non-segregated airspace are set out in Chapter 3, Section 1.
1.8. Temporary Danger Areas
It is recognised that there may be occasions when UAS flights are planned to take place
outside an established DA; in these cases, one or more TDAs could be established to
provide the appropriate segregation.
1.8.1. Maximum Duration
Although the use of TDAs offers a flexible tool for segregating specific portions of airspace
on a temporary basis, it is important to emphasise that segregation effectively denies
airspace to otherwise legitimate users.
Due to their ‘temporary’ nature, TDAs will normally only be established to cover UAS
activities up to a maximum period of 90 days. The formation of a TDA must not be viewed
as a convenient means of establishing segregated airspace for routine, repetitive and/or
long-term activities however; such requests will require the establishment of a permanent
segregated airspace structure, and so will be subject to the Airspace Change Process, as
detailed in CAP 1616. TDAs will not be routinely ‘reissued’ to cover periods beyond their
original lifespan.
1.8.2. Application Requirements
Requests for the establishment of TDAs to support UAS operations are to be forwarded to
SARG Airspace Regulation via the following email address:
[email protected]
Any queries relating to TDAs should also be directed to this address
In order to allow time for the appropriate approval and notification to take place, a
minimum of 90 days’ notice is required. In cases where larger volumes of segregated
airspace are required, particularly when the airspace extends to higher altitudes, an
extended notification period of up to 120 days is more appropriate. Applications with less
than 90 days’ notice may be considered, but will be taken on a case-by-case basis and
any approval/rejection decision will be largely biased towards the likely potential for impact
on other airspace users. Applications must contain the following information:

 A clear description of the requirement for the TDA;
 Details of the volume of airspace required, including coordinates;
 Details of the required hours of operation;
 Details of the airspace management procedures that will be employed (ATC,

DACS/DAAIS, Flexible Use of Airspace practices, NOTAM procedures, etc.);
 Details of the TDA Sponsor, including contact details for multiple on-site contacts;
 Details and evidence of the consultation and engagement (including potential affected
stakeholders) that has taken place. In addition, details and evidence of the responses
from the above process must be provided. Please note the 90 days’ notice will only
commence after full consultation and engagement evidence is provided;
 Details of the type(s) of Remotely Piloted Aircraft that will be flown within the airspace,
in particular the status of any airworthiness approvals/exemptions.
1.8.3. TDA Sponsorship
The requirement for sponsorship of a TDA is identical to that required for any other DA.
Details regarding DA sponsorship, including Terms of Reference, are contained in the
SARG Airspace Regulation Policy Statement ‘Danger Areas’.
1.8.4. Decision/Approval
The decision on whether or not to approve the establishment of a TDA rests with the
CAA’s Group Director, Safety and Airspace Regulation. In some circumstances, this
authority may be devolved to another member of the CAA’s Airspace Regulation Team.
1.8.5. Implementation
Planned TDAs will normally be implemented and promulgated to airspace users via UK
Aeronautical Information Circulars (AIC). In cases where there is insufficient time left to
promulgate a TDA via the normal AIC method, full details of the TDA will be issued via a
detailed Notice to Airman (NOTAM). In addition, a document containing text and a diagram
in a similar format to the AIC will be placed within the ‘News’ section on the Home page of
the NATS AIS website.
Planned TDAs will be activated via NOTAM and should be done so at least 24 hours
before the activation time of the TDA. This is crucial to allow other airspace users, and air
navigation service providers the opportunity to plan accordingly.

1.9. UAS Operating in Controlled Airspace and Flight Restriction

Zones
Whilst permission is not required for a small UAS to operate in controlled airspace (if
outside an FRZ, and in compliance with the applicable articles of the ANO), there are still a
number of considerations that must be taken into account when operating in such areas.
Major airports exert a major influence over the characteristics of the overall airspace
structure and often require that any pilots operating at low-level under VFR adhere to
notified routes and procedures to avoid traffic conflict. This is particularly true of VFR
helicopter flights in and around London, which are often under active control and confined
to a route-structure with changing altitude limitations. Information on such low-level VFR
helicopter route structures is provided in the Aeronautical Information Publication (AIP)
and portrayed on Helicopter Route VFR charts, for example the London Control Zone
chart (Scale 1: 50,000, Series GSGS 5542). Operators are strongly advised to have a
current copy of these charts when operating nearby.
Due to their small size and ability to operate out of small sites in towns and cities, SUA are
particularly difficult to see against an urban backdrop versus the relatively much larger size
of a manned aircraft. The majority of SUA do not have an anti-collision beacon (although
they may have other lights of lesser illumination - typically LEDs) and they are not currently
required to be fitted with a transponder. The small size and the open-framework,
symmetrical structure of a multi-rotor SUA means that it may not be clearly visible until at a
much closer distance than would be the case between two manned aircraft, particularly
when the SUA is hovering or moving slowly. Sighting of a SUA from another aircraft is
likely to be a ‘late sighting’ with reduced time to alter course.
Therefore, in addition to maintaining direct VLOS and, where required, keeping to a height
of no more than 400 feet above the surface, operators of SUA of any weight must avoid
other airspace users at all times. This is particularly relevant when operating near the
London helicopter routes due to the higher density of low level traffic; remote pilots should
operate no higher than strictly necessary for the operation.
Many unlicensed helicopter landing sites also exist, including hospital helipads, as well as
numerous Police helicopter and air ambulance flights. Such aircraft may loiter at low-level
or land and take off unexpectedly. All of these types of helicopter operations may therefore
be affected by SUA operations particularly when approaching to land or departing from a
site; SUA operators must take active precautionary measures to avoid affecting the safety
of other airspace users. Such measures should involve keeping sufficiently clear to avoid
any avoiding action being necessary by either party, or any distraction or change in
mission to the other party, i.e. aborting an air ambulance landing due to a UAS sighting.
It should also be noted that ANO Article 94 states that the Remote Pilot of an SUA ‘may
only fly the aircraft if reasonably satisfied that the flight can safely be made’ and that they

‘must maintain direct, unaided visual contact with the aircraft for the purpose of avoiding
collisions’. In practical terms, SUA of any mass could present a particular hazard when
operating near any aerodrome or other landing site due to the presence of manned aircraft
taking off and landing.
NOTAM action at each site is generally not required due to the typically small scale,
duration and operating limitations of SUA operations. Such a requirement must, however,
form part of the operator’s risk assessment process, particularly outside of controlled
airspace and when several SUA will be operating together (‘swarming’).
1.9.1. Prohibited and Restricted Areas
Prohibited Areas and Restricted Areas, as notified in the AIP apply to unmanned aircraft
(irrespective of their size) as well as manned aircraft. Where approval is required to enter
these areas, permission must be sought, by contacting [email protected].
UAS flight within the London Restricted areas EG R157 (Hyde Park), EG R158 (City of
London) and EG R159 (Isle of Dogs) must be approved by requesting an Enhanced Non
Standard Flight (ENSF) permission. Procedures for requesting this are set out on the
NATS Website. Additional details can be found in the AIP, in ENR 1.1, section 4,
paragraph 4.1.8. This will also involve authorisation from the Diplomatic Protection Group.
1.9.2. Flight Restriction Zones
Flight Restriction Zones are implemented at a the majority of UK aerodromes (a complete

list can be found in the AIP, and on the DroneSafe Website) the purpose of which is to
enhance safety for other airspace users within the vicinity of an aerodrome. In order to
operate within these areas, permission must be sought from the appropriate authority.
Currently, the NATS AUP (aup.nats.aero) provides an online platform to submit requests
to operate within FRZs around some NATS aerodromes, other NATS aerodromes may
require a NSF submission (https://www.nats.aero/do-it-online/non-standard-flight-nsf-
applications/). Other aerodromes may simply require a telephone call. An approval in
principle will generally be issued before, which must normally be followed by an on the day
approval from the appropriate air traffic service unit, or aerodrome operator. In some
cases, a standing agreement may be appropriate, and agreed by both parties, which
grants permission on a standing basis for a specific operation.
FRZs are defined in article 94 of the ANO and comprise three sections:
 The Aerodrome ATZ
 Runway Protection Zones (RPZs)

 Additional Boundary Zones
The ATZ is an existing airspace structure, which applies to manned aircraft, and is a 2 or
2.5 NM radius cylinder which extends to 2000 ft above aerodrome level, centred around
the centre point of the longest runway.
The RPZs are rectangular blocks, starting at the runway threshold and extending out 5 km
along the extended runway centreline, which are 1 km wide and extend to 2000 ft above
aerodrome level.
The Additional boundary zones exist where the airfield boundary +1 km line extends
outside the ATZ. This additional volume is the ‘additional boundary zone’ This also
extends to 2000 ft above aerodrome level.
Figure 7 – Gatwick airport Flight Restriction Zone
These three areas make up the overall FRZ, for which permission to fly within must be
obtained from the ATC or AFIS unit or from the aerodrome operator if no ATC/AFIS is
present.
Permission to fly above 400 ft within the FRZ may be granted by the ATC or AFIS unit,
without requiring further permission from the CAA, providing the flight remains entirely
within the FRZ. If no AFIS or ATC unit is present, then the aerodrome may not permit a
UAS flight above 400 ft within the FRZ, and a CAA permission is required.
All FRZs are published graphically on www.dronesafe.uk, and in raw data formats within

the AIS.
1.9.3. London Restricted Areas EG R157, R158 and R159
The Air Navigation (Restriction of Flying) (Hyde Park) Regulations 2017, Air Navigation
(Restriction of Flying) (City of London) Regulations 2004 and Air Navigation (Restriction of
Flying) (Isle of Dogs) Regulations 2004 lay down restrictions on aircraft operations (which
include SUA) within three defined airspace areas:
 EG R157 (vicinity of Hyde Park),

 EG R158 (vicinity of the City of London) and
 EG R159 (vicinity of the Isle of Dogs).
These Restricted Areas are described in the AIP in ENR 5.1 and are marked on current
VFR charts. The restrictions require, with certain exceptions, that no aircraft fly below
1,400 feet Above Means Sea Level (AMSL) within these areas unless in accordance with
an ENSF clearance issued by the appropriate ATC unit.
The procedure for gaining an ENSF clearance for these Restricted Areas is described in
AIP ENR 1.1 and the procedure to obtain the clearance is facilitated by NATS. Operators
can utilise the web-based application process at the NATS website as above and will then
need to comply with any conditions imposed by the clearance. Operators must note that
the ENSF process also involves security considerations that would apply to any flight by a
SUA whether or not engaged in aerial work or equipped for surveillance or data
acquisition. The ENSF process may take up to 28 days before the grant of an approval.
 CAP 393 Air Navigation: The Order and the Regulations17.
 UK AIP Aeronautical Information Publication.
 Regulation (EU) 923/2012 (Standardised European Rules of the Air).
 EASA Decision 2013/013/R of 17 July 2013 (Acceptable Means of Compliance (AMC)

and Guidance Material (GM) for Implementing Regulation (EU) 923/2012 of 26
September 2012)
17 CAP393 sets out the provisions of the Air Navigation Order as amended together with Regulations made under the Order. These
Regulations are The Rules of the Air Regulations, The Air Navigation (General) Regulations, the Air Navigation (Cosmic Radiation)
(Keeping of Records) Regulations, the Air Navigation (Dangerous Goods) Regulations and a number of permanent Air Navigation
(Restriction of Flying) Regulations. It also contains the provisions of the Civil Aviation Authority Regulations.


CAP 722 Chapter 5 | Operations Cross Border Operations
Cross Border Operations
2.1. Scope
For the purposes of this guidance, international boundaries are considered to be

coincident with lateral FIR/UIR boundaries.
2.2. Policy
UK UAS operators planning to operate beyond an international FIR/UIR boundary must

comply with the regulatory and ATM requirements applicable to the territories over which
the UAS is flown; these may differ from UK requirements. Whilst the CAA will provide
guidance on cross border ATC procedures, including detailing the arrangements for those
areas of airspace where ATS provision is delegated either to or by the UK. Guidance on
foreign national procedures is to be sought from the appropriate State National Aviation
Authority (NAA), and any permissions or authorisations are to be sought directly from that
NAA in this regard. This requirement stems from Article 8 of the Convention on
International Civil Aviation ('Chicago Convention'), which states that:
 "No aircraft capable of being flown without a pilot shall be flown over the territory of
a contracting State without special authorisation by that State and in accordance
with the terms of such an authorisation. Each contracting State undertakes to insure
[sic 18] that the flight of such an aircraft without a pilot in regions open to civil aircraft
shall be so controlled as to obviate danger to civil aircraft".
For the purposes of the Convention the territory of a State shall be deemed to be the land
areas and territorial waters adjacent thereto under the sovereignty, suzerainty, protection
or mandate of such state (Chicago Convention Article 2).
ICAO requirements concerning the authorisation of UAS flight across the territory of
another State are published at Appendix 4 to ICAO Annex 2, Rules of the Air.
3rd Country operators wishing to operate within the UK, outside the normal provisions of
the ANO, must make an application to the UK CAA in this regard. They will have to
demonstrate to the CAA using suitable evidence that they can safely comply with the
applicable UK regulations in this regard. These applications to the CAA will be assessed
on a case by case basis for suitability.
18
.ICAO use of “insure” should read “ensure”

CAP 722 Chapter 5 | Operations ATM Procedures
ATM Procedures
3.1. Scope
Air Traffic Services (ATS) in the UK are provided by personnel who are suitably trained
and qualified to provide services at one or more of the three levels of provision: Air Traffic
Control, UK Flight Information Services and Air/Ground Communication Service. It is not
possible to anticipate all of the issues and queries relating to ATS integration that will
inevitably arise during the future development of UAS and their operational procedures.
Any enquiries for further guidance or to establish the UK policy on a particular issue must
be made to the CAA.
This section provides guidance on the policy associated with the provision of Air Traffic
Services within UK airspace.
3.2. Policy
Individual ATS units may provide services within clearly defined geographic boundaries
(such as a specific portion of airspace) or may provide services within a general area (for
example, in the vicinity of an aerodrome).
The rules pertaining to aircraft flight and to the ATS provided will be determined by a
number of factors (including airspace categorisation, weather conditions, aircraft flight
rules and type of ATSU).
Not all aircraft within the same geographic area will necessarily be in communication with
the same ATSU or operating under the same rules.
It is important that those managing UAS operations are familiar with the relevant rules and
procedures applicable within any airspace through which the aircraft will be flown.
UAS operation is expected to be transparent to ATS providers. The pilot will be required to
respond to ATS guidance or requests for information, and comply with any ATC
instruction, in the same way and within the same timeframe that the pilot of a manned
aircraft would. These instructions may take a variety of forms, for example, to follow
another aircraft or to confirm that another aircraft is in sight.
International regulations and standards require that any new system, procedure or
operation that has an impact on the safety of aerodrome operations or ATS shall be
subject to a risk assessment and mitigation process to support its safe introduction and
operation. Where an operator intends to operate a UAS in UK airspace it will be required
to provide a safety assessment demonstrating that associated hazards to other airspace

CAP 722 Chapter 5 | Operations ATM Procedures
users have been identified, that the risks have been assessed and either eliminated or
reduced to a level which is at least tolerable and is as low as reasonably practicable
through ATS and/or other measures.
Where it is intended to operate a UAS in segregated airspace such a safety assessment

must reflect measures intended to reduce the risk of mid-air collision between UAS and
between UAS and manned aircraft. The safety assessment (which may also be presented
in the form of a safety case or ATS sub-section of a broader UAS OSC) would be
expected to include safety arguments concerning ATS and/or other measures to reduce
the risk of accidents resulting from unplanned incursions into the segregated airspace by
manned aircraft and unplanned excursions from the segregated airspace by the UAS.
Further information about the various levels of ATS and the services available from
 ATS units can be found in the following documents:
 CAP 493 Manual of Air Traffic Services Part 1.
 CAP 797 Flight Information Service Officer Manual.
 CAP 452 Aeronautical Radio Station Operator's Guide.
 CAP 774 UK Flight Information Services.
Further information about the classification of airspace and flight rules can be found in
CAP 32 UK Aeronautical Information Publication.
Further information about radiotelephony procedures can be found in CAP 413

Radiotelephony Manual.
Further guidance on the conduct of safety assessments relating to ATS aspects of UAS
operations can be found in CAP 760 Guidance on the Conduct of Hazard Identification,
Risk Assessment and the Production of Safety Cases: For Aerodrome Operators and Air
Traffic Service Providers.

CAP 722 Chapter 5 | Operations Emergency ATM Procedures
Emergency ATM Procedures
4.1. Scope
The guidance below outlines the requirements for an operator of a UAS in UK airspace to
include robust provision for ATM aspects of the efficient handling of relevant UAS
emergencies.
Pre-planned arrangements for emergency manoeuvring of UAS, including manoeuvre into

emergency orbit areas, emergency landing areas, ‘cut-down’ points and ditching areas,
must be developed in consultation with CAA Airspace Regulation, who will coordinate with
associated ANSPs and other elements within the CAA Safety and Airspace Regulation
Group (SARG).
4.2. Policy
In accordance with the overarching principle that UAS operation is expected to be

transparent to ATS providers, the ATM handling of emergencies involving UAS will be
expected to follow the same process as that for manned aircraft with the air traffic
controller/Flight Information Service Officer / Air-Ground radio operator providing
assistance to the Remote Pilot in order to recover and/or land the UAS without injury to life
and, where possible, without damage to property. However, the absolutely overriding
objective in any emergency situation is the safety of human life. ATM procedures for
dealing with UAS emergencies must, therefore, focus on assisting the Remote Pilot to
resolve the situation without endangering other airspace users or people on the ground.
Although the ATS provider can offer assistance, ultimate responsibility for concluding a
UAS emergency safely must rest with the Remote Pilot.
UAS operators must, as a minimum, develop procedures which provide for the emergency
notification of the relevant ATM agencies in the event that guidance of a UAS is lost or
significantly restricted. Such notification must include the last known position, altitude and
speed of the aircraft and sufficient additional information, such as endurance, which would
enable other airspace users and aerodrome operators to be alerted to the hazard. Such
notification arrangements must be reflected in the UAS operator’s safety assessment.

CAP 722 Chapter 5 | Operations Emergency ATM Procedures
Further information about ATS arrangements for dealing with aircraft emergencies can be
found in the following documents:
 CAP 493 Manual of Air Traffic Services Part 1.
 CAP 797 Flight Information Service Officer Manual.
 CAP 452 Aeronautical Radio Station Operator's Guide.
 CAP 774 UK Flight Information Services.
Further guidance on the conduct of safety assessments relating to ATS aspects of UAS
operations can be found in CAP 760 Guidance on the Conduct of Hazard Identification,
Risk Assessment and the Production of Safety Cases: For Aerodrome Operators and Air
Traffic Service Providers.

CAP 722 Chapter 5 | Operations Aerodrome Operating Procedures
Aerodrome Operating Procedures
5.1. Scope
The ANO does not require UAS operations to take place from aerodromes licensed by the
CAA. This section applies to those UAS operations that take place at licensed
aerodromes.
It is not possible to anticipate all of the issues and queries relating to aerodrome
operations that will inevitably arise during the future development and operation of UAS.
Any enquiries for further guidance or to establish the UK policy on a particular issue must
be made to the CAA.
5.2. Policy
The aerodrome licence holder is required to demonstrate how the safety of those aircraft
requiring the use of a licensed aerodrome will be assured when UAS operations are
permitted at the aerodrome.
The operation of UAS at a licensed aerodrome must be conducted in accordance with
safety management requirements set out in the Aerodrome Manual of the aerodrome. This
Manual, which forms a core element of the aerodrome’s Safety Management System
(SMS), contains the safety policies, accountabilities, responsibilities and procedures to
facilitate the safe operation of the aerodrome.
It is essential that those managing UAS operations are familiar with the relevant rules and
procedures applicable at the aerodrome from which they operate. The aerodrome licence
holder must provide an operating manual or other documents pertaining to the operation of
UAS at that aerodrome, to ensure that risks from all aspects of the intended UAS
operation are assessed and mitigated.
Aerodrome and UAS operating procedures may be subject to audit by the CAA.
Information about the licensing and operation of aerodromes can be found in the following
documents:
 CAP 168 Licensing of Aerodromes.
 CAP 738 Safeguarding of Aerodromes.

CAP 722 Chapter 5 | Operations Incident and Accident Procedures
Incident and Accident Procedures
6.1. Scope
The safe operation of UAS is as important as that of manned aircraft, and third-party injury
and damage to property can be just as severe when caused by either type of aircraft.
Proper investigation of each accident, serious incident or other occurrence is absolutely
necessary in order to identify causal factors and to prevent repetition. Similarly, the sharing
of safety related information is critical in reducing the number of occurrences. The limited
operational experience with UAS in civil applications makes such investigation particularly
relevant.
This section outlines the principles that must be employed with regard to the reporting and
further investigation of occurrences involving the operation of all civilian unmanned aircraft
within UK airspace; it also covers occurrences involving UK-registered unmanned aircraft
that take place within the airspace of other nations.
6.2. Definitions
The current UK definitions of 'Accident' and 'Serious Incident' originate from Regulation
(EU) No. 996/2010, which in turn are directly linked to the ICAO Annex 13 definitions.
An Accident is defined as: ‘An occurrence associated with the operation of an aircraft
which, in the case of a manned aircraft, takes place between the time any person boards
the aircraft with the intention of flight until such time as all such persons have disembarked
or, in the case of an unmanned aircraft, takes place between the time the aircraft is ready
to move with the purpose of flight until such time it comes to rest at the end of the flight
and the primary propulsion system is shut down, in which:
a) a person is fatally or seriously injured as a result of:
 being in the aircraft, or,
 direct contact with any part of the aircraft, including parts which have become
detached from the aircraft, or,
 direct exposure to jet blast, except when the injuries are from natural causes,
self-inflicted or inflicted by other persons, or when the injuries are to stowaways
hiding outside the areas normally available to the passengers and crew; or

b) the aircraft sustains damage or structural failure which adversely affects the structural
strength, performance or flight characteristics of the aircraft, and would normally
require major repair or replacement of the affected component, except for engine
failure or damage, when the damage is limited to a single engine (including its
cowlings or accessories), to propellers, wing tips, antennas, probes, vanes, tires,
brakes, wheels, fairings, panels, landing gear doors, windscreens, the aircraft skin
(such as small dents or puncture holes) or minor damages to main rotor blades, tail
rotor blades, landing gear, and those resulting from hail or bird strike (including holes
in the radome); or
c) the aircraft is missing or is completely inaccessible.’
A Serious Incident is defined as: 'An incident involving circumstances indicating that there
was a high probability of an accident and associated with the operation of an aircraft
which, in the case of a manned aircraft, takes place between the time any person boards
the aircraft with the intention of flight until such time as all such persons have disembarked
or, in the case of an unmanned aircraft, takes place between the time the aircraft is ready
to move with the purpose of flight until such time it comes to rest at the end of the flight
and the primary propulsion system is shut down.'
NOTE: The difference between an accident and a serious incident lies only in the result.
A Reportable Occurrence is defined as: 'Any incident which endangers or which, if not
corrected, would endanger an aircraft, its occupants or any other person.'
6.3. Policy
Any person involved (as defined under Regulation (EU) No. 996/2010) who has knowledge
of the occurrence of an accident or serious incident in UK airspace must report it to the
AAIB. Such persons include (but are not limited to) the owner, operator and remote pilot
of a UAS.
 All occurrences must be reported to the CAA under EU376/2014
 All accidents or serious incidents must also be reported to the AAIB under
EU996/2010.
The following aircraft categories are specifically covered by the Occurrence Reporting
Regulation (i.e. all occurrences must be reported):
 Any aircraft operated under an Air Operator's Certificate granted by the CAA;
 Any turbine-powered aircraft which has a Certificate of Airworthiness issued by the

CAA.

Although these categories would appear to exclude the vast majority of UAS applications,
all occurrences related to UAS operations which are considered to have endangered, or
might have endangered, any aircraft (including the subject unmanned aircraft) or any
person or property, must still be reported to the CAA via the MOR Scheme. This applies
equally to all UAS categories, regardless of the aircraft's mass or certification state. It also
includes UK registered UAS operating outside UK airspace.
UAS Operators should report any event in line with Regulation (EU) 376/2014 and IR
2015/1018. Whilst some of the listed occurrences would clearly only apply to manned
aviation, many will apply equally to UAS, in particular those associated with the operation
of the aircraft; there are also failure modes that are UAS specific. In addition to those listed
in EU376/2014 or IR2015/1018, other, more UAS-specific, reportable occurrences include
events such as:
 Loss of control/datalink – where that loss resulted in an event that was potentially
prejudicial to the safety of other airspace users or third parties.
 Navigation failures;
 Pilot station configuration changes/errors:
 between Pilot Stations;
 transfer to/from launch control / mission control stations;
 display failures.
 Crew Resource Management (CRM) failures/confusion;
 Structural damage/heavy landings;
 Flight programming errors (e.g. incorrect speed programmed);
 Any incident that injures a third party.
Additional guidance on MORs (Mandatory Occurrence Reports) and VORs (Voluntary

Occurrence Reports) can be found on the CAA website: https://www.caa.co.uk/Our-
work/Make-a-report-or-complaint/MOR/Occurrence-reporting/
6.3.1. Occurrence Analysis and Follow-up
Occurrences identified by UAS operators as potential safety risk as a result of its

investigation and analysis should be transmitted within 30 days form the initial date of
notification of the occurrence. Included in the update should be preliminary analysis
performed and, if any; action to be taken due to the outcome of the analysis. Furthermore,
the UAS operator should submit the final results of their analysis no later than three

months form the date of initial notification of the occurrence.
UAS operators should consider the size and complexity of their operation when selecting a
reporting system. For smaller less complex UAS operators the CAA recommends UAS
operators submit reports using the EU Aviation Reporting Portal. For larger more complex
operators the CAA recommends UAS operators use a reporting software solution that
meets the requirements found on the CAA website. https://www.caa.co.uk/Our-work/Make-
a-report-or-complaint/MOR/Reporting-Software-Solution/
Guidance on reporting via the EU Aviation Reporting Portal can be found in CAP1496.
The Civil Aviation (Investigation of Air Accidents and Incidents) Regulations 1996.
Regulation (EU) No. 996/2010 on the investigation and prevention of accidents and
incidents in civil aviation.
Regulation (EU) 376/2014 on the reporting, analysis and follow-up of occurrences in civil
aviation.
ICAO Annex 13 – Aircraft Accident and Incident Investigation.
6.5. Points of Contact
6.5.1. Accident / Serious Incident:
Air Accidents Investigation Branch

Farnborough House
Berkshire Copse Road
Aldershot
HANTS
GU11 2HH
24-hour Accident/Incident reporting line: +44 (0) 1252 512299
(Administration/general enquiries)
Tel: +44 (0) 1252 510300
Fax: +44 (0) 1252 376999

6.5.2. Mandatory Occurrence Reporting:
Safety Data
Aviation House
West Sussex
RH6 0YR
E-mail: [email protected] with copy to [email protected]

Reporting Portal: www.aviationreporting.eu or via the MOR Reporting pages on the CAA
website

CAP 722 Unmanned Aircraft System Operations in UK Airspace - Guidance & Policy

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Safety and Airspace Regulation Group

Unmanned Aircraft System Operations in UK

Civil Aviation Authority

First edition of CAP 722, 29 May 2002

The latest version of this document is available in electronic format at www.caa.co.uk

September 2019 Page 3

September 2019 Page 4

September 2019 Page 5

1.8. Continued airworthiness processes 104

September 2019 Page 6

5.2. Policy 132

September 2019 Page 7

Seventh Edition September 2019

Seventh Edition July 2019

Sixth Edition March 2015

 Complete restructure of the document.

 Updates to all Chapters (including Abbreviations and Glossary of Terms).

 Introduction of a Concept of Operations Approach (ConOps)

 Introduction of an Approval Requirements Map.

 Removal of Military Operations Chapters.

September 2019 Page 8

 Addition of Alternative Means of Compliance to demonstrate Operator Competency.

Fifth Edition 10 August 2012

 Revised Abbreviations and Glossary (also reflected throughout the document),

 Introduction of a Human Factors chapter.

 A complete rewrite of the ‘Civil Operations, Approval to Operate’ chapter.

 Amendments to civilian Incident/Accident Procedures.

 A complete revision to Section 4 (Military Operations), which reflects the formation

Fourth Edition 6 April 2010

Expanded guidance regarding the reporting of incidents/occurrences involving the

September 2019 Page 9

Third Edition 28 April 2008

With an ever-increasing number of manufacturers and operators, it is vital that the

Revisions in this Edition

Impending Changes to Regulation

September 2019 Page 10

Third Edition incorporating amendment 2009/01 14 April 2009

Second Edition 12 November 2004

September 2019 Page 11

In advance of further changes to this document, updated information is contained on the

September 2019 Page 12

The UAS Guidance documentation is structured as follows:

Chapter 2 Authorisations and Approvals

CAP722 A Operating Safety Cases

Section 1 UAS OSC Volume 1 – Operations Manual Template

Section 2 UAS OSC Volume 2 – UAS Systems Template

CAP722 B National Qualified Entity

September 2019 Page 13

For queries relating to the content of CAP 722:

For matters concerning operations or approvals:

Shared Service Centre (UAS)

Telephone: 03300 221908

September 2019 Page 14

Abbreviations and Glossary of Terms

ACAS Airborne Collision Avoidance System

ADS-B Automatic Dependent Surveillance Broadcast

AFIS Aerodrome Flight Information Service

AIC Aeronautical Information Circular

AIP Aeronautical Information Publication