Consultation Hub

It is vital that CAP 632 Operation of Permit-to-Fly Ex-Military Aircraft on the UK Register remains up-to-date and relevant, and that the CAA’s guidance material in these areas remains as proportionate and clear as possible.

Despite the circumstances related to COVID-19 on the flying community more generally, we nevertheless continued our review of CAP632 and asked for feedback on proposed amendments. 

We compiled a draft of CAP 632 Edition 8 and consulted on it over six working weeks from 30 April to 12 June 2020.

We received a total of 469 unique comments to the draft CAP from 23 respondents. All respondents were from the ex-military aircraft community including display pilots, operators, flying display directors, and other organisations. Three responses were formal submissions from representative bodies or associations.

All the comments except one conveyed some sort of change. Of these:

• most (82%) were minor, suggesting revised wording or highlighting minor drafting points. Many of these were comments were duplicated between respondents; and  
• the other 18% were more substantive in nature, calling for rethink of our approach or suggesting a change to the underlying policy.

We accepted 358 of the all the comments (over 76%).

Of the 385 minor comments received, we accepted 78%. Most of these comprised rewording content for clarification, and we have tried to take a balanced view on what would be helpful. Several respondents requested changes to text that most readers thought was satisfactory. Others called for revision to text that we had carefully drafted following extensive discussions internally or with external organisations, and did not feel that the change would bring greater benefit than the drafting based on the prior in-depth collaborative analysis.

Of the 83 comments that we regarded as more substantive, we implemented just over 70%. A significant proportion of this group asked for consolidation of the content, and the cross-referencing (rather than duplication) of material read-across from other CAA documents or processes. One example of this concerned overlap with CAP1395, Safety Standards Acknowledgment & Consent, which is also in the process of being updated following a recent public consultation. As a result of these comments, we undertook a major redraft of this CAP, and believe the results address most of the substantive comments received.

Regarding that redraft, we have made the following broad categories of changes since the previous edition, resulting in a noticeably shorter document:

• References to Safety Standards Acknowledgement and Consent (SSAC) have been removed from this publication and incorporated into CAP1395 “Safety Standards Acknowledgement and Consent”.
• Re-structure and condensing of content
• Removal of duplication where possible
• Introduction of SRG1872 for initial OCM applications and variations
• Introduction and reference to the CAA Scheme of Charges
• Simplification of operator responsibilities
• Introduction of an accountable manager role
• Introduction of Continuing Airworthiness Coordinator role
• Introduction of Mandatory Occurrence Reporting (MOR) in line with CAP382
• Insertion of Fully Remunerated Flying Training application form (previously AIC 55/2016 which will be deleted)
• Simplification of Operational systems requirements (eg for ejection seat & ATRE process).
• Clarification on when passengers can be flown
• Clarification on recommendations, and guidance as to what is regulation
• Introduction of an example Dual Check form
• Removal of chapter on Safety Management Systems and replaced with a link to CAP1059
• Introduction of guidance for Commercial Operation

Regarding the 24 more substantive comments that we elected not to implement, most asked us to expand on material that we thought was covered adequately either in this document or elsewhere. Several comments also involved review or revision to underlying policy such as airworthiness, operations regulation or in some cases amendment to the Air Navigation Order (ANO), all of which are beyond the scope of this consultation. However, we welcome inputs to those wider policies, as and when these are released for public consultation.

Overall, we thank you for your comments and hope our revised CAP will be more workable for operators, pilots and others.

CAP 632 Operation of 'Permit-to-Fly' ex-military aircraft on the UK register (Edition 8) has now been published

The purpose of the consultation was to ask you to help us identify volumes of controlled airspace in which the classification could be amended to better reflect the needs of all airspace users on an equitable basis. The consultation asked respondents to each identify two volumes of airspace where amendments to current structures and access arrangements should be considered. Respondents were asked to identify the location of the opportunities as well as the flight level, and time of the day and year when the classifications could be amended. We asked respondents to provide a rationale and supporting evidence for their suggestions. In addition to the online consultation, the CAA held four public engagement events including three dedicated roundtables with groups that represent airspace users.

We had 604 responses to the consultation, which we have published where we have been given permission to do so. Most respondents identified themselves as members of the general aviation community, accounting for 557 of the 604 responses. Geographically, 274 respondents were in the South East, including those who represented an organisation based there; the remainder was spread across the UK.

Respondents were asked to submit up to two volumes of airspace each. With over 600 responses received, the CAA assessed over 1000 volumes of airspace submitted through the consultation. These opportunities corresponded to 57 locations across the UK. The full list of these locations is included in our report on the consultation, CAP 1935, available at the bottom of this page.

On the whole respondents expressed support for the concept and intention of the classification review and several comments were received on the engagement opportunity presented by the consultation. Despite welcoming the review, several concerns were expressed that it will fail to deliver any tangible benefits to the general aviation community.

There was a high level of dissatisfaction expressed over the visualisations included in the consultation. It was felt that the visualisation images did not provide a clear indication of activity in the various controlled airspace areas shown and questioned why movement data  was not supplied in the consultation.

Although support was expressed for the need to modernise and rationalise UK airspace to create structures which are safe, efficient and proportionate for all users, some respondents were concerned with the implications of continually increasing the level of controlled airspace. Similarly, concerns were expressed that the current restrictions on general aviation movements had resulted in flights being funnelled into tight corridors, creating pinch-points.

There was support shown for the introduction of using airspace flexibly, and several respondents commented on the need for technological solutions, such as electronic conspicuity, to be implemented to support its deployment. A number of respondents cautioned however that introducing flexible airspace around busy airfields could cause confusion and create a significant additional risk.

Strong comments were received from the general aviation community on airspace change decisions taken within the last few years, and the resulting detrimental effect they have had on the community and their ability to use airspace. There were also suggestions, in particular in the roundtables, that policies concerning lower airspace should be reviewed.

We have published a report on the consultation CAP 1935, available at the bottom of this page.  The CAA has also published CAP 1934, a consultation on our proposed procedure for amending airspace classifications. Once this new procedure has been agreed and implemented, we will use that to review the potential volumes of airspace submitted through this initial consultation and identify those where we think the classification could be amended in line with safety and security requirements.

In the consultation report we:

• list the airspace volumes suggested by respondents as candidates for a classification change;
• include case studies on three of the suggestions received, in which we illustrate how we might treat them under our proposed procedure, to illustrate how we would take the suggestions forward once the new procedure is in place (noting that this might change, when we amend our proposed procedure after the consultation);
• respond to each of the themes raised by respondents to explain our perspective and, where we agree that action is needed, what we will do. This includes a commitment to review the Controlled Airspace Containment Policy (January 2014) and the Application of ICAO Airspace Classifications in UK Flight Information Regions (November 2014).

The purpose of this consultation was for you to give the CAA views on our proposal of extending paid-for initial pilot training to be conducted using certain aeroplanes which hold a UK national Permit-to-Fly (PtF).

We presented a comprehensive, yet proportionate set of requirements to mitigate risks and where possible align safety standards for airworthiness to a comparable level of safety with those already in the flight training environment.

The consultation was drafted by the CAA with input from members of the GA community, asked seven main questions and was open for six weeks. 

We received a total of 441 responses of which 425 were unique. Where possible, the unique responses were categorised in order to identify and weight the responses accordingly. We have prepared a Comment Response document (CAP1928) that summarises the results.

Following this consultation results analysis, we have been liaising internally within the CAA and CAP1928 sets out how this project will be now undertaken.