Acceptable Means of Compliance and Guidance Material to UK Regulation (EU) 2019/947

Thank you to everyone who took the time to respond to this consultation.

We received 411 comments during the consultation period, including 84 conceptual comments, and 48 comments that were outside the scope of the consultation.

The following questions and themes were noted during the consultation.

1. Can we add in the regulatory requirements themselves, into this document?
   
   For this consultation, we had to publish the AMC/GM in a specific format. However, we will be publishing the AMC/GM, once finalised, using a new Easy Access format on the CAA website, which will include the regulatory requirements, the AMC and the GM, all in one place.
   
   For reference, this new format has recently been applied to the Sailplanes regulations (UK Regulation (EU) 2018/1976).
    
2. Can we change the term ‘unmanned’ to a gender neutral term?
   
   The term ‘unmanned’ is the term used in the regulation, and so is the term used within the AMC/GM document. We have, however, introduced a short explanation into CAP 722 to explain the use of the terms UAS, and RPAS.
    
3. Missing requirements
   
   It became clear from some responses that not all respondents realised that the AMC/GM supports the regulation, and does not contain all the requirements in their entirety. This document must be read alongside the regulatory requirements themselves, summarised in CAP 1789A. We hope that the work described in point 1, above, will help resolve this.
    
4. Risk assessment methodology
   
   We received some comments on the Specific Operations Risk Assessment (SORA) methodology. This is currently under development, separately to this AMC/GM update, and will be subject to a separate consultation.
    
5. CAP 722H
   
   A number of respondents noticed references to CAP 722H, which is not currently published. This will be published, along with a number of other CAP updates, at the same time as this AMC/GM.
    
6. CHIRP
   
   We received a number a requests to add guidance on the voluntary reporting mechanism CHIRP into AMC. Because this AMC specifically relates to the reporting regulation,  the AMC and GM here must only relate to that. We have, however, added in a guidance section on CHIRP to CAP 722, which will be published at the same time as the AMC/GM and other CAP 722 updates.
    
7. Remote Pilot Competence in the Specific Category
   
   We received a number of comments on the GVC pilot competence requirements. We are currently undertaking a project to establish new remote pilot training and assessment requirements for the Specific Category. Although out of scope for this consultation, we will feed these comments into that work, which will be subject to a separate consultation in 2023.

We reviewed each comment, and have amended the Acceptable Means of Compliance (AMC)/Guidance Material (GM) where necessary.

We are finalising the AMC and GM, and the subsequent CAP updates, and plan to release these in November. We will alert you when these are live.