Operation of Permit-to-Fly ex-military aircraft on the UK register

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