We utilise UAV’s, more commonly known as drones, to collect images and video for commercial gain. That means we have to have permission granted by the Civil Aviation Authority to do so. In this post we explain what that actually means and what we had to do to obtain that permission.
For anyone gaining “valuable consideration” from utilising UAV’s, the Civil Aviation Authority (CAA) require that Permission for Commercial Operations (PfCO) is applied for and granted. They have a set of requirements that have to be met before they will grant permission for commercial operations. They are as follows:
- Operations Safety Case
The company must create an Operations Safety Case (Operations Manual) that is specific to that company and it’s intended and actual operations and submit this to the CAA for approval.
- Approved Training
Any pilot in command who is operating the UAV’s for the company must have undertaken and successfully passed a training course with a National Qualifying Entity training provider that is approved by the CAA. The course is in two stages, ground school and the flight assessment.
- Operational Currency
The pilot in command must have and maintain operational currency with the UAV’s they are operating. This is currently set at a minimum of 2 hours operation every quarter.
- Log Keeping
The company must also create logs for the UAV, pilots, batteries and UAV maintenance. These must be kept up to date and accurate.
Public Liability Insurance must be in place to cover the drone flight operations.
Our path to obtaining Permission for Commercial Operations took around 8 months, from start to finish. There is a considerable financial outlay in obtaining a PfCO and also a lot of time needs to be invested too. It wasn’t something that was easy to achieve but it does allow us to operate lawfully. We feel it demonstrates our commitment to what we do and shows we take our responsibilities seriously. We have to renew our permissions every 12 months with the CAA so it isn’t a case of jumping the hoops and then taking the foot off the pedal either.
The First Step – Some Confusion
Our path to gaining permission for commercial operations began with doing a lot of reading on how we could achieve this. Stuart had extensive experience with flying UAV’s as a hobbyist but wanted to fly them commercially. Once we identified the requirements, we knew we had to undergo CAA approved training. So we looked at CAA approved NQE training provider for the training course. There were quite a few to choose from, prices were similar and there didn’t seem to be much to differentiate one from the other. Add in the fact that there are different qualifications to choose from too. RPQ-s, BNUC-s to name a couple.They all pretty much cover the same ground training wise, so the choice wasn’t easy.
Stuart chose Resource Group, the qualification they offer is the RPQ-s (Remote Pilot Qualification – small). It was after having read some positive comments on a hobbyist UAV forum that Stuart chose Resource Group. The course came in five parts;
Ground School – Web Based Learning
The web based learning stage requires that you work through the course content before attending the classroom phase of training, there are practice tests to prepare you for the ground school exam. The ground school covers several modules;
Basic Map Reading
Latitude and Longitude
Principles of Flight
Air Law Responsibilities
Airmanship and Aviation Safety
Ground School – Classroom based and exam
Stuart had to attend a 4 day session at York, where the classroom lessons were taught and the final ground school exam was held. The classroom lessons covered what should have been learned in the web based learning. The exam covered all the modules covered. The Operations Safety Case was discussed and we were briefed on what was expected of us in terms of content and scope for the OSC. We then started creating the OSC after completing the ground school.
After successfully completing the ground school phase of the course, Stuart had to book his flight assessment. Candidates are expected to have gained enough flight hours with the UAV they intend to use for the flight assessment before the assessment. This is a practical test of the pilots ability to handle the UAV and also a test of the pilots ability to conduct the operational procedures they must conduct for every flight. The assessment requires demonstrating safe operating in all intended flight modes, so for Stuart this comprised of GPS assisted and Atti (altitude hold) Mode.
We had to submit our Flight Reference Cards, emergency procedures and Volume 2 of the Operations Safety Case before we could book the assessment, these also had to be approved by Resource Group prior to booking. The flight assessment is conducted as if it was a commercial flight operation, so a pre deployment survey, on-site survey and risk assessment had to be conducted and approved by the assessor before Stuart moved on to the flight phase. In the flight phase, Stuart had to perform several manoeuvres with the UAV and also perform simulated emergency procedures.
Operations Safety Case – Creation and review
On successful completion of the ground school we had to start writing the Operational Safety Case, this was the hardest stage for us. Basically you are creating a set of procedures and operational practices that ensures all flight operations are conducted safely and responsibly. The OSC isn’t something that can be drawn up with a template, it’s specific to each company. We had to submit a draft to the training provider for approval, then action any amends that were flagged. The writing of the OSC was difficult at times, but the process is definitely beneficial as it forces you to consider how you are going to operate safely. In addition to writing the OSC, we had to create other documents and procedures that have to be used for flight operations, the use of these documents has to be detailed in the OSC;
Flight Reference Cards
Logs for UAV, batteries, pilot, maintenance
Writing the OSC was the most time consuming of the steps we had to take to obtain the PfCO. From start to completion, including amends, it took probably 3 months. We lost some time due to the fact that the CAA had made some revisions to their literature that meant we had to amend our OSC to reflect those changes. Once the OSC was completed and approved by our training provider we were ready to move on to the final stage.
Once we had passed the ground school, flight assessment and had our OSC approved we were ready to submit our application for the PfCo to the CAA. The application was made on our behalf by our training provider, we just had to complete the necessary paperwork for the application, provide payment details for the application and pass that on with the OSC and logs to the training provider.
The application we made hit some hurdles along the way. The CAA at the time of our application were stating a 60 day processing period for applications. So we waited patiently for the 60 days to pass. They passed and we hadn’t heard anything back. So we made a call to the CAA, it wasn’t looking good initially as they said they couldn’t find any record of our application. This caused some panic to say the least! After another couple of calls getting nowhere, it turned out that our application had been misfiled and they had found it. To be fair, they fast tracked the processing after this and we got an email with our PfCO granted shortly after. After we received the PfCo and were ready to commence commercial operations, we took out our public liability insurance policy and got ourselves geared up and ready for business.
Doesn’t end there though!
Obtaining the PfCo is a step in becoming commercial UAV operators but it isn’t a closed book on what is required. We have to renew our PfCo yearly and we have to maintain accurate logs and records and ensure we are maintain operational currency in the UAV platforms we operate. We also have to stay abreast of changes to legislation that covers what we do and make any operational or administrative amends to ensure we continue operating lawfully.
Making use of what we’ve learned
The whole process of obtaining a PfCO can seem drawn out and at times it can be frustrating. At the end of the process though, there is definitely a sense of achievement and it does force you to think about operational safety as a commercial entity operating UAV’s, which is essential! We put what we’ve learned during this process into practice every day here at Eye in Sky Media, we do so not just because we are legally obliged to, we also do it because what we have learned in the process is essential for us to operate safely as commercial UAV operators. We put operational safety above all other concerns, without exception.
By holding our PfCo we can demonstrate that we operate in compliance with current legislation and have procedures and operational practices in place to give you assurance that we aren’t a cowboy operation and we do take our responsibilities seriously.
To find out more about the services we offer as CAA approved commercial UAV operators, you can visit our services page on this website.
Eye In Sky Media – Our Services