We Asked, You Said, We Did

It is vital that CAP 1724 Flying Display Pilot Authorisation and Evaluation: Requirements and Guidance remains up-to-date and relevant, and that the CAA’s guidance material in these areas remains proportionate, clear and unambiguous.

We asked for feedback from the regulated community on proposed amendments to CAP 1724 ahead of the 2025 display season. 

We compiled a draft of CAP 1724 Edition 7 and consulted on it over four working weeks from 16 January 2025 to 12 February 2025. 

We received a total of 48 unique comments to the draft CAP 1724 from 15 respondents.  

Of all the comments, 27 clearly conveyed some sort of change and 21 were either unclear / not specific or suggested no changes, many being purely comments.  21% of all the comments supported the proposed amendments.

Of the 27 conveying a change, 17 were textual in nature, suggesting revised wording or highlighting minor drafting / clarification points, several being duplicated between respondents.  The other 10 comments were more substantive, calling for some sort of change of the underlying policy. 

We accepted 4 of the 27 comments suggesting some sort of change (15%).  3 of these comprised of rewording content or the addition of further information for additional clarification, we have tried to take a balanced view on what would be helpful.  The other comment concerned a minor policy change.

Of the remaining 23, 8 concerned points that were already covered elsewhere (either in this CAP or CAP403), 7 concerned issues that are beyond the scope of this CAP, 1 suggested a change that had already been made, 2 were unclear / not specific and 5 were aimed at sensitive text that we are unable to change.

Regarding the 10 more substantive comments we received, we implemented 1. Of those we elected not to implement, some were beyond the scope of CAP 1724, others were covered adequately either in this document or elsewhere, some concerned suggestions for unacceptable changes to policy and it was considered that the remaining might have further unintended consequences.

We have produced a final version of CAP 1724 Edition 7 which was published on 10 March 2025. 

For comments on the proposal that the CAA introduces a deviation concerned with flight crew alerting on a large transport aeroplane.

The UK CAA is consulting on a Deviation that is applicable to CS-25 Large Aeroplanes. This Deviation provides the compensating factors to reach an acceptable level of mitigation to allow issuance of the type certificate with the non-compliance to CS 25.1322.

This is based the use of an approach to the cockpit philosophy on flight crew alerts which has been approved and is common to previous types certified by the same manufacturer.

The Consultation Paper Deviation UK.DEV.F.0001 Issue 1 provides the full detail of the identified issue, and the associated Deviation.

We received 2 responses.
The first response primarily related to the number of memory actions required, and pilot training when multiple ratings are held.

The second response proposed a number of wording changes aimed at making the text more specific to flight crew alerts, and proposes eliminating some text perceived by the commenter to be redundant. In addition, the commenter considers that CS 25.1322(c)(2) has not been addressed and should be addressed.

We acknowledge the responses and thank the responders for their suggestion.
For response 1, the comment is not incorporated. While the comments are relevant, their incorporation would is not considered to address the intent of the deviation and mitigations presented to the non-compliance.

For response 2, the comment is not incorporated. The deviation scope is considered to be clearly centred around Flight Crew Alerting, and the current text is considered to be clear within this context.

Further, the CAA consider that the text proposed for deletion by the commenter is not redundant, but is necessary and focussed on the requirements addressed by the deviation. CS 25.1322(c)(2) is addressed in Appendix A Table 4.

It is vital that CAP 403 Flying Displays and Special Events: Safety and Administrative Requirements and Guidance remains up-to-date and relevant, and that the CAA’s guidance material in these areas remains proportionate, clear and unambiguous.

We asked for feedback from the regulated community on proposed amendments to CAP 403 ahead of the 2025 display season. 

We compiled a draft of CAP 403 Edition 22 and consulted on it over four working weeks from 09 December 2024 to 03 January 2025.

We received a total of 65 unique comments to the draft CAP 403 from 12 respondents.  

Of all the comments, 44 clearly conveyed some sort of change and 21 were either unclear / not specific or suggested no changes, many being purely comments. 

Of the 44 conveying a change, 27 were textual in nature, suggesting revised wording or highlighting minor drafting / clarification points, several being duplicated between respondents.  The other 17 comments were more substantive, calling for some sort of change of the underlying policy. 

We accepted 12 of the 44 comments suggesting some sort of change (27%). 10 of these comprised of rewording content or the addition of further information for additional clarification, we have tried to take a balanced view on what would be helpful.  The other 2 concerned minor policy changes.

Of the remaining 32, 12 concerned points that were already covered elsewhere (either in this CAP or CAP1724), 8 were comments that were unclear / not specific or concerned issues with formatting that we were unable to replicate, 8 were aimed at sensitive text that had been changed to align with and reflect wider CAA policy and 4 involved suggested changes to underlying policy.

Regarding the 17 more substantive comments we received, we implemented 2. Of those we elected not to implement, some were beyond the scope of CAP403, others were covered adequately either in this document or elsewhere, some concerned suggestions for unacceptable changes to policy and it was considered that the remaining might have further unintended consequences.

We have produced a final version of CAP 403 Edition 22 which was published on 4 February 2025. 

For comments on the proposal that the CAA introduces a special condition to be used for the crashworthiness conditions of a conformal rear centre fuel tank installation on a large transport aeroplane.

The UK CAA is consulting on a Special Condition that is applicable to CS-25 Large Aeroplanes.

This Special Condition is to address the design change that introduces a conformal fuselage structural fuel tank to the aeroplane, also called rear centre tank (RCT), and the unusual design of the RCT should prevent fuel spillage in sufficient quantities to start a serious fire in an otherwise survivable crash event.

The Consultation Paper Special Condition UK.SC.C.0001 Issue 1 provides the full detail of the identified issue, and the associated Special Condition.

We received 1 response.
The response agrees that additional guidance for fuel tank crashworthiness is appropriate and recognised that the proposed special condition is substantively similar to the European Union Aviation Safety Agency (EASA) special condition SC-E25.963-01; however, the responder did not consider that special conditions were necessary to address this novel design feature and that establishing acceptable means of compliance with the introductory requirement stated in 14 CFR 25.963(d), and ensuring the applicant makes every practicable consideration to ensure protection of fuel tanks in more severe crash conditions that exceed, or are not captured by, the conditions specified in 14 CFR 25.963(d)(1) through (d)(5), especially tanks located in the fuselage below the main cabin floor, is an acceptable approach to this novel design feature.

We acknowledge the response and thank the responder for their suggestion. The CAA believes that creating the Special Condition rather than a Means of Compliance provides a stronger, clearer criteria that the aircraft must achieve for this unusual configuration and the specific crashworthiness case, and that aligning with the Certificating Authority’s approach, given the common requirements set on this project, is more appropriate in this case.

For comments on the proposal that the CAA introduces a special condition to be used to protect the cabin occupants during evacuation of fuel tank explosion triggered by an external ground fuel fed fire.

The UK CAA is consulting on a Special Condition that is applicable to CS-25 Large Aeroplanes.

This Special Condition is to address the design change that introduces the conformal fuselage structural fuel tank to the aeroplane, also called rear centre tank (RCT), and the protection of cabin occupants during evacuation, from the risk of fuselage tank explosion triggered by an external fuel fed ground fire.

The Consultation Paper Special Condition UK.SC.E.0001 Issue 1 provides the full detail of the identified issue, and the associated Special Condition.

We received 1 response.
The response agrees that the proposed Special Condition is substantively the same as the equivalent EASA Special Condition and the harmonised FAA Special Condition, the difference with the FAA Special Condition being wording clarification only. The response suggested that CAA should align the CAA Special Condition wording with that of the FAA Special Condition.

We acknowledge the response and thank the responder for their suggestion.
The CAA believes that the wording of the CAA Special Condition is sufficiently clear and that aligning with the Certificating Authority’s Special Condition, given the common requirements set on this project, is more appropriate in this case.

For comments on the proposal that the CAA introduces an equivalent safety finding concerned with degraded flight instrument external probe heating systems on a large transport aeroplane.

The UK CAA is consulting on an Equivalent Safety Finding that is applicable to CS-25 Large Aeroplanes.

This Equivalent Safety Finding provides the compensating factors to reach an equivalent level of safety to direct compliance with requirement CS 25.1326(b)(2) based on the detection of degraded anti-icing performance, through monitoring of the possible erroneous air data - potentially caused by a malfunction of a probe heating system - from one or more probes.

The Consultation Paper Equivalent Safety Finding UK.ESF.F.0001 Issue 1 provides the full detail of the identified issue, and the associated Equivalent Safety Finding.

We received 2 responses.
The first response highlighted the relevance of this proposed ESF to an ongoing investigation into partial probe heater failures on a large aeroplane type. In the referred partial failure, the probe tip could become iced up while the probe body remained ice free. Further, the method of probe heater failure detection during maintenance was not able to reliably detect this partial failure condition. The comment highlighted the relevance to the fundamental issue addressed by the ESF, and the need for the careful consideration and assessment of the scheduled maintenance actions for reliability.

The second response highlighted the need to address common mode faults and the potential for erroneous readings to occur from multiple primary air data systems. The commend further highlighted potential alleviations for common mode failures through system redundancy, dissimilarity, and robust comparator logic within the ADS.

We acknowledge the responses and thank the responders for their suggestion.
For response 1, the comment is not incorporated. Whilst we acknowledge the issue raised is a point of concern, our position is that this is currently covered by the Equivalent Safety Finding by incorporating as a compensation factor the use of DFCS monitoring system and its redundancies, as expressed in points 2.a.1, 2.a.2 and 2.a.3 of the ESF.

For response 2, the comment is not incorporated. The objective of this ESF is to identify compensation factors for the lack of strict compliance with 25.1326(b)(2) considering specific failure modes in which there is a degraded anti-icing performance of these sensors, as expressed in Section 2 of this ESF. To achieve this, the ESF identifies means where the aircraft systems trigger messages to the crew informing about the unreliability of these sensor, triggering suitable operational response in accordance with AFM procedures.

The concerns raised in the comment are part of the technical investigation that is carried out in the systems referred in this ESF in context of other points of CS 25 (eg. 25.1309).

For comments on the proposal that the CAA introduces a special condition to be used for the crashworthiness conditions of a conformal rear centre fuel tank installation on a large transport aeroplane.

The UK CAA is consulting on an Equivalent Safety Finding that is applicable to CS-25 Large Aeroplanes.

This Equivalent Safety Finding provides the compensating factors to reach an equivalent level of safety as an alternative to compliance with CS ACNS.E.TAWS.030 (b)(3), (b)(4), and (e) based on the availability of additional terrain information displayed on other windows of the PFD.

The Consultation Paper Equivalent Safety Finding UK.ESF.F.0002 Issue 1 provides the full detail of the identified issue, and the associated Equivalent Safety Finding.
You Said

We received 3 responses.
The first response concerned the need to ensure specific training in a realistic environment associated with the propose alternative approach. The response also comments that the TID is provided whenever required in both normal and reversionary modes.

The second response described two different scenarios that are perceived by the commenter as effective in implementing SVS and terrain information display. The first scenario refers to a SVS implementation that changes the colour of the terrain when it becomes a threat to the aircraft. The second scenario refers to a top 3D SVS view being supplemented by a bottom HSI view where terrain is represented in green, yellow, red.

The third response raised several comments around the implementation of the proposed mitigating factors. Dependent on the solution implemented, comments were raised including the potential for fore-shortening effects if the terrain information display compresses the SVS, the need for the pilot to integrate the information given on the two displays (SVS and TID), and the ability of the pilot to identify FPV when overlapping terrain.

We acknowledge the responses and thank the responders for their suggestions.
For the first response, the comment is not incorporated. The CAA consider that the training element is out of contest in the ESF, and that the subject of the reversionary mode of the "alerting display" is covered by the current compensating factor in Appendix A section 3.a and the required compliance with the other requirements of the CS ACNS Subpart E that remain applicable.
For the second response, the comment is not incorporated.

The scenarios described are both noted. In particular, the second scenario is considered to be covered within the compensating factors presented which require separate window providing a 2d view of the terrain compliant with CS ACNS.E.TAWS.030 (b)(3) and (b)(4).

For the third response, the comment is not incorporated. The CAA acknowledge the observations presented, however consider that the points raised apply at the design

For comments on the proposal that the CAA continues its existing policy to recognise certain EASA Form 1s as equivalent to CAA Form 1s in certain limited circumstances, namely for maintained parts released by the Original Equipment Manufacturer or authorised agent for use on aircraft falling within the scope of Part-ML, where a component cannot be repaired by an organisation holding a UK approval. Currently this is managed by CAA ORS9 Decision No. 24 that was issued in December 2022 with an expiry date of 31 December 2024. We proposed in the consultation to extend this policy until 31^st December 2029.

To achieve the policy objective the CAA proposed to amend the current end date within Acceptable Means of Compliance (AMC) to UK Regulation (EU) No. 1321/2014 (the UK Continuing Airworthiness Regulation), specifically in Part-145, and Part-ML to reflect the 2029 deadline. The amendments clarify that specified EASA Form 1s (only) are ‘equivalent documents’ as permitted by the terms of the regulation to which the AMC applies.

We received 31 responses.

We received strong support of (90%) for the CAA to continue its policy of recognising certain EASA Form 1s as equivalent to CAA Form 1s in certain limited circumstances.

We received significant support (77%) for the proposed wording of AMC1 ML.A.501(a)(ii) Classification and installation.

We received significant support (70%) for the proposed wording of AMC1 145.A.42(a)(i) Components.

We received comments suggesting that the new decision should be issued indefinitely. This is not considered a viable option as the UK would be unilaterally accepting parts from the EU without any sort of reciprocal arrangement. However, the CAA will review annually the need for the new decision and will continue encouragement for foreign organisations to obtain CAA approval. We will also seek to look at a more permanent solution for beyond December 2029.

We received several comments relating to widening the scope of the decision to include Part-CAMO/Part-M aircraft. This was not in the scope of the original decision and given the targeted requirement of the use of Article 4 (1A) within the UK Regulation (EU) No. 1321/2014, we are unable to extend this provision further outside the scope of Part-ML.

We received comments to clarify where the EASA approved organisation must be located. By means of a typographical correction made to the AMC to align with the original decision, we have clarified within the AMC that it must be an EASA approved organisation based within an EASA member state.

We have decided to issue a new decision following the policy set by the original Decision 24 and thereby amend the current end date to 31^st December 2029 within AMC to UK (EU) Regulation 1321/2014. The new decision will apply as follows:

• Provided that the component is not available from a CAA approved organisation, a maintenance organisation in a state with which the UK has a bilateral safety agreement, or an organisation based in a state with whose NAA the CAA has a working arrangement, components of Part-ML aircraft released on an EASA Form 1 by the component’s original equipment (or their approved agent) manufacturer based in an EASA member state may be fitted to a UK registered aircraft.

We asked for comments on our proposal to make changes to Acceptable Means of Compliance (AMC), Guidance Material (GM), Certification Specifications (CS) and Guidance material (GM) for UK Reg (EU) No 139/2014 regarding the ICAO change to the reporting method of pavement bearing strength from Aircraft Classification Number (ACN) and Pavement Classification Number (PCN) to Aircraft Classification Rating (ACR) and Pavement Classification Rating (PCR).

The consultation for the amendments to Regulation UK (EU) 139/2014 that will also be included in CAP168 closed on the 25 October 2024, there were eight responses. 

Many of the responses  were in the form of questions which are addressed in the responses below. Generally, the proposed changes were accepted.

One key concern was the need for the extension of the PCR applicability date. Following the consultation comments the CAA took quick action to promulgate the PCR extension for both using aircraft and technical evaluations via SkyWise, therefore giving airports more time to plan and finance the required pavement evaluations to become compliant.

Consultation timing 
A comment was made relating to the timing of the consultation being too close to the applicability date.  The CAA recognise the PCR change timing is not ideal and was a result of several factors outside of its control which led to delays not least COVID lockdown and the recent general election both of which slowed down and paused regulatory development. This is a reason that an extension to the applicability date will be announced.

Airport category and complexities 
Comments were received regarding the use of PCR data at different category aerodromes  i.e. non- complex / complex aerodromes with a suggestion that the matrix is only applied to commercial aerodromes, however PCR applies to all licensed and certificated aerodromes with a hard runway operating aircraft over 5, 700kgs, there is no differentiation to the category or complexity of the aerodrome.

Extension to the PCR applicability date
There were several comments relating to the extension of the PCR applicability date. Four of the eight responders requested an extension to the applicable date.  

The CAA had already indicated that applicability date was going to be extended and would be notified after the consultation closed. The extension periods for both U and T compliance will be advised shortly and will likely exceed the suggested time frames suggested by responders providing adequate time to undertake the required evaluations.  
 
Capital costs 
One airport raised the capitol costs of the conversion to PCR T.  The CAA is aware of the costs and planning required to undertake a full technical survey in to meet the requirements for the technical declaration. This is the prime reason that an extension to the applicability date which will be announced, allowing aerodromes to plan for the required testing which also provides the option to spread the cost of the testing program over an extended period. The extension of the PCR applicability is in line with other  states which are also extending applicability deadlines. 

Lack of guidance for U evaluation
Lack  guidance  was mentioned particularly relating to the U method. The use of using aircraft and the ICAO software to perform a calculation for the heaviest aircraft was identified and promulgated as soon as possible once evaluation and training had been undertaken and methods verified at the ICAO Airport Pavement Expert Group by the CAA. 

The CAA provided a webinar on the use of the software packages for PCR calculation and also offered ongoing support on a one-to-one basis for airports with software demonstrations and guidance together with assistance with calculating U values. ICAO Doc 9157 Aerodrome Design Manual Chapter 3 is also a source of guidance CAP168 already contains guidance on PCR calculations which is suitable for both certificated and licensed aerodromes which was promulgated by SkyWise. 

Use of U evaluation until next pavement maintenance 
There were several comments made to the use of U until the next planned maintenance.  The use U is acceptable as long as plans are made to undertake the required technical assessment by the applicability extension deadline date.   Planned maintenance or rehabilitation is the ideal time to undertake technical evaluation depending on how the maintenance plan falls within the revised applicability dates.

ACN/PCN data can still be used until the T evaluation is completed by the deadline, the information will remain in the AIP until the PCR values are notified to AIS. An extension to the revised applicability will be notified, any further request to extend beyond the revised applicability date will be subject to discussion with the allocated aerodrome inspector.

Pressure plate testing may not provide adequate information for the pavement technical evaluation given the subbase requires evaluation via cores, DCP, and GPR surveys.

Training courses 
Regarding training a comment was made relating to training, ICAO training courses are available, the training available is overview and technical for engineers. 

Software suitability
There were comments regarding the suitability of the software packages currently available for PCR calculations.  The software packages do provide output data to perform the PCR calculation for T evaluations including CDF values and life expectancy based on design. Other states are developing software not least the UK which will become available in the near future. 

EMAS 
EMAS and use of existing arrestor beds consideration was highlighted, a question was raised regarding consideration for existing EMAS which are not identified in the proposed CS and if installed to what extent of the RESA can be substituted.  

The intent is to introduce a CS and standard to be met for new EMAS installations. The substitution of RESA is subject to safety assessment and EMAS design intent considering the operations at the aerodrome.  RESA reduction will only be considered for new EMAS installations given EMAS is an engineered solution and is very different from a soft arrester bed.  If current soft beds are employed these remain acceptable in their current form, however,  additional RESA reduction in this application will not be considered.  

There were no negative responses for the inclusion of the CS in 139/2014 and CAP168. 

AGLCS system design 
Comments were received relating to the change to the design of AGLCS and its required financial investment. Comment also referred to the text update to CS ADR-DSN.S.890 requesting if there is an expectation that existing approved AGLCS systems will need safety cases re-evaluated to meet additional requirements where they may present over the existing, or will this apply for new/amended installations?

Adjustments can be  undertaken when a change is made to a system  or its updated or replaced and in consultation with the aerodromes allocated ATM inspectors.

GRF 
There were no comments relating to the proposed amendments to GRF.However, this element will be removed from this task and added at a future date, this is due to the potential of further changes by ICAO prior to issue of the State letter which is now estimated as 2027. 

CS ADR-DSN.D.335
Comment received relating to the revision of CS ADR-DSN.D.335 being the inner transitional is less ‘demanding’ at 1:3 vs 1:7, it’s still tight for larger aircraft tails, concern was raised as this contradicts some of the taxiway separation and holding position distance tables which no longer fully protect against larger aircraft tails as mobile obstacles. 

The introduction of new OLS surfaces will help with the operational assessment and establishment will address these points. The new OLS surfaces will become applicable in 2030.  The required work to update AMC / GM and CAP168 will commence in 2025 with the aim for adoption well in advance of the applicability date, therefore mitigating the problem, any penetrations will always be subject to an aeronautical study.

AMC1 ADR.OPS.B.090
A comment was received relating to operation of higher code aircraft and impacts to existing permissions. 

If higher code aircraft when factored into the aircraft mix do not exceed CDF 1 the pavement life should be calculated  by the PCR software for the current and forecasted aircraft mix at the aerodrome. 

Overlays prior to the end of forecasted design life will alter the PCR and CDF at which point they should be recalculated. Should the traffic mix alter the PCR and CDF calculations the process should be repeated by using the PCR software.  

Current permissions are unlikely to be affected but the effect of pavement should be assessed if the higher code aircraft when evaluated in the aircraft mix causes the CDF to exceed CDF1 which is then an overload operation. 

Continuous overloading of the pavement will affect the overall pavement life, its planned maintenance and lead to early failure.  It is the responsibility of the aerodrome to effectively manage this element within the scope of the overload requirements and aerodrome pavement inspection and maintenance procedures. 

Following the consultation comments the CAA took quick action to promulgate the PCR extension for both using aircraft and technical evaluations via SkyWise, therefore giving airports more time to plan and finance the required pavement evaluations to become compliant.

The CAA does not envisage additional rule making  activity regarding the implementation of the change areas outlined in the consultation, the update will consist of AMC/ GM amending or adding to existing provisions. 

We asked industry and academia to apply to participate in three hydrogen working groups created as part of the Hydrogen Challenge:

• H2Wo(1) Hydrogen Propulsion Systems – hydrogen combustion, hydrogen electric and hydrogen fuel system.
• H2Wo(2) Hydrogen Aircraft Safety & Certification – standards as guidance, Special Conditions and Human Factors/Flight Ops.
• H2Wo(3) Aerodromes and Airports – infrastructure, fuelling/de-fuelling and airport safety

These will facilitate collaboration with industry and academia to improve understanding of hydrogen-related risks in aviation, identify gaps in regulations and policies, and propose new recommendations to develop net-zero regulations and policies.

We received a total of 117 applications to join the one or more of the three working groups.

All applicants were contacted and asked which groups they wanted to attend. Selected applicants will be sent invitations for the first meetings which we hope to hold in October 2024.

We ran a consultation, CAP2974G, from 13 March to 22 May 2024 asking the UK General Aviation (GA) community for their views on our proposed strategic direction for pilot licensing and training simplification - Gyroplanes.

The consultation covered the following themes:

• Differences training and whether to add these into the Air Navigation Order 2016 as requirements rather than suggested minimum hours.
• Crediting of theoretical knowledge (TK) and flight training towards gaining an NPPL microlight as previously allowed under CAP804.
• Relaxing the restricted Flight Instructor Gyroplane (FI(G)) supervision to also include the local area to allow some flexibility in allowing restricted FI(G) to be able to gain the experience to remove the restriction.
• Maintaining the privileges of the gyroplane rating and whether to align with the new suggestions in the Aeroplane consultation paper.
• ATO requirement for FIC and how this can be made more proportionate for FIC(G).
• Creating gyroplane specific TK examinations and moving them to the eExams system.

We received 20 responses to this consultation. All respondents answered the survey questions and some left detailed comments.

• Differences training: The vast majority agreed with the proposals to incorporate the differences training, currently in Standards Document 44 (SD44), into the Air Navigation Order 2016 as requirements.
• Crediting of TK and flight training towards gaining NPPL(M): Nearly all respondents agreed with both of these proposals with only 1 individual being undecided on the flight training proposal.
• Relaxing the supervision of restricted FI(G): 70% of respondents agreed with the new proposed wording to relax the supervision and include the local flying area.
• Maintaining privileges: Only 4 respondents had a view on this topic.
• ATO requirement for FIC: 50% of respondents agreed with our approach.
• Creating gyroplane TK and moving onto eExams platform: These proposals received mixed views from respondents.

We will be proceeding with the next phase of this project to develop and move forward with proposed changes:

• We will begin work on drafting the proposed amendments to the ANO, in co-operation with the Department for Transport. 
• We will begin work on updating Standards Document 44 to capture the changes.
• We will update the PPL(G) Air Law and Gyroplane Technical examination papers and reformat the NPPL(A) Microlight examination papers for gyroplanes. Once updated these will be sent to all Ground Examiners for Gyroplanes.
• We will commence a project to amend CAP1667, to align with the DTO requirements.

We have published our consultation response document, setting out these findings in more detail: CAP3032G

We ran a consultation, CAP2974F, from 13^th March 2024 to 22^nd May 2024 asking the UK General Aviation (GA) community for their views our proposed strategic direction in the second phase of the Licensing and Training Simplification project- Sailplanes.

The consultation covered the following themes:

• Adding the term ‘Gliding Club’ to the list of definitions in Article 2 of the Sailplane Regulations.
• Developing procedures and privileges to authorise student pilots who are following a training course to gain an SPL to exercise limited privileges without the supervision of an instructor, before they meet all the requirements that are necessary for the issue of an SPL.
• Propose changes to theoretical knowledge exams including the number of exams and the validity periods.
• Amend Acceptable Means of Compliance (AMC) for powered sailplanes to include partial engine failure.
• Develop a Basic Instructor privilege within SFCL similar to the current BGA Basic Instructor rating and make necessary amendments for aerobatic and self-launching for instructors.

We received 586 responses to this consultation. Most respondents answered the survey questions and a number also left additional comments. The consultation questions were worded in such a way to form a survey that could be quantitatively analysed. 

• We received significant support to add the term ‘Gliding Club’ to the list of definitions in Article 2 of the assimilated Sailplane Regulations UK (EU) 2018/1976, defining it as a club affiliated to the British Gliding Association (BGA), which is created with the aim of promoting aerial sport and leisure aviation.’
• We received significant support to develop procedures and privileges to authorise student pilots who are following a training course to gain a SPL to exercise limited privileges without the supervision of an instructor before they meet all the requirements that are necessary for the issue of an SPL.
• We received significant support to make changes to theoretical knowledge exams including the number of exams and the validity periods.
• We received significant support to amend Acceptable Means of Compliance (AMC) for powered sailplanes to include partial engine failure following an AAIB safety recommendation.
• We received significant support to develop a Basic Instructor privilege within SFCL similar to the current BGA Basic Instructor rating.

We received significant support to make necessary changes to amend the privileges of the Flight Instructor to remove the requirement for the Flight Instruction to hold advanced aerobatic privileges if instructing for basic aerobatic privileges as well as amending the privileges of the Flight Instructor to include self-launch in the launching methods.

We will be proceeding with the next phase of this project to develop and move forward with proposed changes.

• We will begin work on drafting the proposed amendments to the Sailplane Regulations, in co-operation with the Department for Transport.
• We are working towards a legislative slot in Spring 2025.
• We will also liaise with internal colleagues to ensure that our systems, internal instructions documents and all staff are ready for the implementation of these changes.

In some areas, we need to develop appropriate Acceptable Means of Compliance (AMC), Guidance Material (GM) and other CAA publications (CAPs) to support the planned changes to regulation. These will be consulted on, where necessary, in late 2024 or early 2025.

We have published our consultation response document, setting out these findings in more detail: CAP3032F

We ran a consultation, CAP2974B, from 13 March to 22 May 2024 asking the UK General Aviation (GA) community for their views on our proposed strategic direction for pilot licensing and training simplification - Balloons.

The consultation covered the following themes:

• Next steps and embedding the reforms for Part-BFCL.
• Licensing for private ballooning.
• Commercial balloon licensing.
• Instructor and Examiner requirements.

Theoretical knowledge changes.

We received 128 responses to this consultation. Most respondents answered all survey questions and a number of those also left detailed comments. There were a small number of respondents that did not answer a large proportion of the questions.

• Next steps and embedding Part-BFCL: We received a large number of individual comments in response to our 3 requests for input. Details of these and our decisions can be found in the Consultation Response Document (CRD)
• Licensing for Private ballooning: Respondents were largely in favour of the majority of proposals relating to Private ballooning, with the exception of the recency requirement and frequency of flight training with a Flight Instructor balloon (FI(B))
• Commercial balloon licensing: We received majority support for proposals regarding pre-requisite hours for commercial ballooning, minimum hours requirement when moving from one envelope to the next, mandatory ground school, making proficiency checks mandatory every 2 years and mandatory refresher training every 5 years. There was also support for having 2 separate commercial ratings.
• Instructor and Examiner requirements: Respondents indicated strong support for all proposals relating to instructor and examiner licensing. Details of which can be found in the CRD.
• Theoretical knowledge changes: Again, there was strong support to all proposed changes to theoretical knowledge examinations and their validity periods.

• We will be proceeding with the next phase of this project to develop and move forward with proposed changes.
• We will now begin work on drafting the necessary documents, required by the Department for Transport (DfT), to implement changes to the ANO and Part-BFCL.
• We are working towards a legislative slot in Spring 2025.
• We will also liaise with internal colleagues to ensure that our systems, internal instructions documents and all staff are ready for the implementation of these changes.
• Due to the volume of work and resource constraints in the legislative programme, some areas of policy relating to balloons will not be progressed until 2026. These include changes relating to:
  • Theoretical knowledge examinations.

We have published our consultation response document, setting out these findings in more detail: CAP3032B

We ran a consultation, CAP2974E, from 13 March to 22 May 2024 asking the UK General Aviation (GA) community for their views on our proposed strategic direction for pilot licensing and training simplification - Helicopters.

The consultation covered the following themes:

• Combined licence documents for both the sub-ICAO and ICAO compliant private helicopter licences.
• Proposed amendments to theoretical knowledge (TK) examinations including number of exams and validity periods as well as the use of mobile devices for planning.
• Flight instructor theoretical knowledge and ways of improving the requirements.
• Other issues within the helicopter category that we may not have considered.

We received 37 responses to this consultation. All respondents answered the survey questions and some left detailed comments. There was however 1 respondent who did not answer the TK question.

• Combined licence documents: We received significant support for both proposals to issue a combined licence document for both ICAO compliant and sub-ICAO helicopter licences.
• Amendments to TK:
  • Number of exams: The most popular suggestion was to combine exams into 7 rather than the current 9 however there was significant support to keep the current requirements of 9 examinations.
  • Use of mobile devices: We received overwhelming support to use mobile devices in planning training and also navigation exercises.
  • Validity periods: 62% of respondents agreed that we should amend the validity period of exams to 36 months rather than the current 24 month validity.
• Flight Instructor TK: We received 19 comments to this request for suggestions. A selection of them can be found in the consultation response document (CRD).
• Other issues: 21 respondents left comments on this section. A selection can be found in the CRD.

• We will be proceeding with the next phase of this project to develop and move forward with proposed changes.
• We will now begin work on drafting the necessary documents, required by the Department for Transport (DfT), to implement changes to the ANO and Part-FCL.
• We are working towards a legislative slot in Spring 2025.
• We will also liaise with internal colleagues to ensure that our systems, internal instructions documents and all staff are ready for the implementation of these changes.
• Due to the volume of work and resource constraints in the legislative programme, some areas of policy relating to helicopters will not be progressed until 2026. These include changes relating to:
  • Theoretical knowledge examinations

We have published our consultation response document, setting out these findings in more detail: CAP3032E

We ran a consultation, CAP2974A, from 13 March to 22 May 2024 asking the UK General Aviation (GA) community for their views on our proposed strategic direction for pilot licensing and training simplification – Aeroplanes.

The consultation covered the following themes:

• Revising the PPL(A) qualifying experience in line with ICAO Annex 1
• Feedback on the future class rating system
• Options for the future sub-ICAO aeroplane licence
• Review of class rating revalidation requirements
• Theoretical knowledge changes
• Other subjects including the Instrument Rating, sailplane and aerobatic ratings, and the use of non-Part 21 aircraft.

We received 640 responses to this consultation. Most respondents answered all survey questions and a number of those also left detailed comments. There were a small number of respondents that did not answer a large proportion of the questions.

• The PPL(A) qualifying experience: We received strong support for the proposed changes, including making the PPL qualifying experience more flexible and allowing credit from flight time previously gained on microlights.
• Class rating system: Most respondents were in favour of examining this area further.
• Sub-ICAO aeroplane licence: Most favoured adopting a single sub-ICAO licence for the UK.
• Class rating revalidation: Most favoured retaining a flight experience element for the revalidation of the SEP, TMG and microlight class ratings, and alignment of the requirements across all three ratings.
• Theoretical knowledge: We received feedback on the number of PPL exams, and support for our changes to exam pass validity periods.
• Other subjects: We received support for all our proposals.

• We will be proceeding with the next phase of this project to develop and move forward with the proposed changes.
• We will now begin work on drafting the necessary documents, required by the Department for Transport (DfT), to implement changes to the UK Aircrew Regulation and the Air Navigation Order.
• We are working towards a legislative slot in Spring 2025.
• We will also liaise with internal colleagues to ensure that our systems, internal instructions documents and all staff are ready for the implementation of these changes.
• Due to the volume of work and resource constraints in the legislative programme, some areas of policy will not be progressed until 2025, with legislation likely in 2026. These include changes relating to:
  • Theoretical knowledge;
  • Class rating system;
  • Instrument rating and IMC rating.
• We have published our consultation response document, setting out these findings in more detail: CAP 3032A

In some areas, we need to develop appropriate Acceptable Means of Compliance (AMC), Guidance Material (GM) and other CAA publications (CAPs) to support the planned changes to regulation. These will be consulted on, where necessary, in late 2024 or early 2025.

For comments on the proposals for new and amended Acceptable Means of Compliance (AMC) and Guidance Material (GM) in UK Regulation (EU) 965/2012 relating to Locations of Aircraft in Distress – Aeroplanes.

The implementing rule CAT.GEN.MPA.210 Location of Aircraft in Distress – Aeroplanes was introduce in Statutory Instrument (SI) 2022 No.1235. However, there was no supporting AMC or GM included at that time and AMC 1 CAT.GEN.MPA.210 and GM1 and GM 2 CAT.GEN.MPA.210 were proposed.

In addition, the following amendments to AMC/GM were also proposed:

• AMC and GM for CAT.IDE.A and H.280 Emergency locator transmitter (ELT) and AMC2 CAT.IDE.A.285 and AMC1 CAT.IDE.H.300(b)(3) & CAT.IDE.H.305(b) Flight over water & Survival equipment provide more information on the specific requirements of distress tracking ELT (ELT(DT))s.
• AMC and GM for SPA.HOFO.145 Flight Data Monitoring has been updated to provide details of industry good practice.
• AMC2 NCC.IDE.A.215 Emergency locator transmitter (ELT) has been amended to reference AMC2 CAT.IDE.A and H.280 for details of the applicable types of ELTs and AMC2 CAT.IDE.A, H.280 AMC2 SPO.IDE.A.190  on crash survivability and homing-signal capability applicability.
• AMC2 NCO.IDE.A.170 and  AMC2 SPO.IDE.H.190 Emergency locator transmitter (ELT) is amended to enable an ELD(AD) to be either a stand-alone beacon or an inseparable part of a deployable recorder.

Furthermore,  additional GM were included regarding Global Report Formatting for reporting runway conditions that were inadvertently missed in a previous revision to UK Regulation 965/2012.

We received no comments on the CAA proposals during the consultation.

Since the consultation, ICAO published State letter (AN 11/1.1.29-24/16) dated 24 June 2024. This letter informed states that the location of an aircraft in distress repository (LADR) is now operational. The LADR is a critical part of the Global Aeronautical Distress and Safety System (GADSS), providing the means to store and make available all information related to the position of an aircraft in distress, as described in Annex 6 — Operation of Aircraft, Part I — International Commercial Air Transport — Aeroplanes, 6.18. CAT.OP.MPA.210 complies with this ICAO standard.

In addition, ICAO required operators to register a focal point account with OPS Control/LADR. As a result, we have included an additional GM3 CAT.OP.MPA.210 to provide the necessary information for operators.

The proposed changes to the AMC/GM to UK (EU) Regulation 965/2012 (the UK Air Operations Regulation) are necessary as they provide enhanced supporting information for the following areas:

• Definitions
• Aircraft tracking system – aeroplanes,
• Location of an Aircraft in Distress - aeroplanes,
• Emergency Locator Transmitter (ELT),
• Flight over water & survival equipment helicopters,
• Life rafts, survival ELTs, and survival equipment on extended overwater flights,
• Flight Data Monitoring (FDM) Programme

The CAA therefore intends to publish these changes through the Official Records Series 4 process.

The Civil Aviation Authority (CAA) consulted on a proposed policy position for the recognition and implementation of Atypical Air Environments (AAEs).

We received a total of 239 responses from across the aviation community including UAS commercial and recreational users, military, emergency services, Air Navigation Service Providers, GA, other formal aviation related bodies and organisations as well as the general public.

We published a Consultation Reply, that includes details of the responses and our Unmanned Aircraft Operations in an Atypical Air Environment: Policy Concept.

The purpose of this public call for input engagement, on improving the degree of alignment between the UK Flight Information Services and the International Civil Aviation Organisation (ICAO) Flight Information Service (FIS) provisions in the UK, was to support the implementation of the Airspace Modernisation Strategy (AMS). We have an obligation to review and optimise our degree of alignment with ICAO provisions.  That allows us to demonstrate our air traffic services provision is complementary to that of our neighbouring states, thereby enhancing overall flight safety and providing an adaptable ‘visual flight rules (VFR) or instrument flight rules (IFR)’ solution to service recipients in classes E and G airspace. 

In this ‘Call for Input’ engagement we sought stakeholder views to inform our development of a proposal and asked a series of follow-up questions linked to the proposal and the alignment, content and provision of air traffic services in the UK.  We provided the opportunity for stakeholders to offer their views and opinions on this subject and to provide narrative answers accordingly.  In addition, we offered stakeholders a chance to submit written proposals and counter-proposals as well as a chance to discuss the proposal with CAA staff.

We received 187 responses in total.  In broad terms, respondents were 60% service recipient (pilot/aircraft operator); 40% service provider (ANSP, ATCO, FISO, other).  Most respondents, 82%, were offering personal views, the remaining 18% of respondents were submitting on behalf of an organisation.  Overall, 88% of respondents supported the intent of the proposal; some respondents proceeded to elaborate why they had answered yes/no and provided reasons and caveats to their responses.

There were some useful and varied opinions from the full range of stakeholders, which supports our assertion that the UK does indeed have a complex and nuanced FIS position which is at odds with other states.

The opinions offered were dependent upon stakeholder’s own task(s) and output(s) as well as location and experience (this applies especially overseas, and for those advocating improvement to the delivery of UK Flight Information Services by adopting a hybrid methodology taking the best elements of the French, US and, in particular, the German system).

Of those respondents familiar with CAP 774 (UK Flight Information Services), and who receive/provide UK Flight Information Services in accordance with it, 62% felt it meets their operating requirements and is currently fit for purpose.  In addition, 73% of respondents felt that the current edition of CAP 774 was easy to assimilate whereas 27% did not.

Of those CAP 774 services, respondents were familiar with the four air traffic services in descending order: Basic Service, Traffic Service, Deconfliction Service then Procedural Service.

The majority of respondents, 66%, answered that all elements of CAP 774 should be reviewed.

The preponderance of respondents answered that, in descending order, Deconfliction advice; Vectors; Level Allocation; and Sequencing should be considered for inclusion as provisions of future UK Flight Information Services.

In addition, 70% of respondents stated that elements of ICAO Doc 4444 PANS-ATM should be better aligned with, or emphasised, within the future UK Flight Information Services.

Similarly, 74% of respondents stated that the CAA should simplify the operational delivery of UK Flight Information Services, many of the respondents offered opinions as to how this might be achieved.

83% of respondents suggested that the CAA should use technology to improve the delivery of UK Flight Information Services, with many respondents offering opinions on how this might be achieved.

89% of respondents thought it is important to retain a verbal agreement, between ATS provider and recipient, stating the type of service an aircraft is in receipt of.

There were lots of comments about commensurate airspace requirements to balance any potential future changes to UK Flight Information Services where their current application is used in risk mitigation.  In addition, respondents provided opinions and comments upon Lower Airspace (Radar) Services ranging from current provision to how it might be provided in the future.

It is important to the CAA that everyone has an opportunity to voice their opinion on matters that could affect them. For this reason, we asked for comments on this proposed change process.  We welcomed comments from every sector of the community. This includes the general public, government agencies and all sectors of the aviation industry, whether as an aviator, aviation consumer and/or provider of related products and services.

So, what next?  We will conduct deeper analysis on the responses, additionally, here is our engagement response document (CAP 3007) which contains some data analysis and excerpts from stakeholder responses for broader consumption.  We have already commenced the safety assurance process to make sure any future changes are delivered safely.  We shall then develop technical solutions and options, prior to a subsequent full stakeholder consultation.  Thereafter, once an option is agreed upon, we shall need to work on aviation-wide training, implementation, deployment, and a post implementation review.

Lastly, we are very mindful of the need for synchronicity.  The AMS offers a number of future changes and improvements, and the alignment of UK Flight Information Services with ICAO FIS is but one of them; we very much acknowledge the ability and capacity of all stakeholders to absorb these changes and will continue to proactively engage to better understand these challenges.

We asked for feedback from the General Aviation (GA) community on the challenges facing pilots in obtaining an active carbon monoxide (CO) detector, the importance of protecting passengers from CO, the role that maintenance plays in combatting CO, and whether active CO detectors ought to be mandatory for some operations.

CAP 2975 was published in February 2024 and was consulted on over a four-week period. The consultation included nine specific technical questions as well as an opportunity for respondents to provide free-text comments.

We received a total of 271 separate responses to the consultation. The Comment Response Document (CAP 3024) provides a summary of the responses received and the decisions taken as a result.

Based on the findings from this consultation and the extensive work done in this area over the last four years, the CAA will be issuing a directive requiring an active CO detector to be present in specified piston engine aircraft operations. The requirement will follow closely the proposal set out in CAP 2975, but will be modified to take into account the comments received in the consultation.

The CAA will not, at this time, introduce mandatory CO concentration checks in piston engine aircraft maintenance programmes beyond what is already specified by aircraft manufacturers and UK Reg (EU) No.1321/2014 Annex Vb (Part-ML), Minimum Inspection Programme (MIP).

The CAA will publish additional guidance on selecting an appropriate active CO detector, where and how to securely position devices in aircraft, how to respond to alerts, as well as guidance on exposure levels and thresholds for alarms.

We asked for feedback on the CAA’s view on Handling Rules for VTOL Aircraft Using Battery Power for Propulsion.

We received a total of 16 responses. Eight respondents have disagreed or expressed concern with our proposal to not allow recharging of batteries used for propulsion with passengers embarking, on board or disembarking. Some of the same respondents felt it is the operators that should decide if recharging with passengers onboard is appropriate, with manufacturers’ input.

Multiple respondents noted the proposal would have a negative impact on the business model of VTOL operators by resulting in longer turnarounds and ground handling times, risking the viability of the industry.

One respondent explicitly was in favour of equating swapping out of batteries to maintenance.

Two respondents stressed that approach to this issue should be risk-based, not prescriptive, to account for design, procedural, and ground mitigations that will be in place.

Two respondents asked for more specifics on firefighting and rescue standards and regulations, including which and how much of substance to use when putting out lithium-ion battery fires, and standardised firefighting techniques for this type of fire.

We have considered the comments submitted in response to the call for feedback on the proposed approach to Handling Rules for VTOL Aircraft Using Battery Power for Propulsion.

The CAA is committed to enabling new aviation business models in the UK, subject to appropriate levels of safety being maintained. The CAA’s approach to regulating these new business models remains risk and evidence based.  Due to the novelty of VTOL aircraft and their infrastructure we consider that there is insufficient data to support the use of some practices when handling batteries used for propulsion.

In its statement the CAA proposed that batteries used by VTOL for propulsion should not be recharged with passengers on board. We consider that recharging lithium-ion batteries with passengers on board a VTOL aircraft would be analogous to refuelling using avgas and wide-cut fuel with passengers on board.

Both avgas and wide-cut fuel are difficult to handle due to the amounts of explosive vapours that they generate. If a fire was to occur, it would result in high risk to passengers and likely damage the aircraft. Due to these risks, refuelling using these fuels with people on board is not permitted.

While a lithium-ion battery thermal runaway event is a low probability event, if it did occur, could result in a very powerful and fast-spreading fire and the outcome of that fire could be more significant compared to conventional fuels, such as wider area of damage and toxic byproducts. Academic research suggests that even if fire is not present, a lithium-ion battery experiencing a thermal runaway can generate large amounts of toxic fumes. This can have negative health consequences and inhibit efforts to evacuate passengers.

At times, the process of thermal runaway could last days. Even during recharging, lithium-ion batteries can create gasses that are toxic and flammable by nature. As the capacity of lithium-ion batteries grows, so will the potential damage that can be caused.

Lithium-ion batteries are therefore currently being treated as high risk. We will review our approach as more data is made available to us about the technologies being used and the mitigation methods applied to address the risks to persons and property on the ground.

We acknowledge that technological and procedural measures can go a long way to mitigate risks associated with recharging batteries used for propulsion. The CAA will therefore consider potential mitigations, such as a proposal by respondents to allow development of operating procedures by the OEMs and operators, but subject them to CAA review and approval. This statement will be reviewed to account for technological progress in energy storage where new types of batteries may have a lower risk profile compared to lithium-ion batteries.

We are aware of the challenges posed by lithium-ion batteries in VTOL aircraft, especially in the context of Rescue and Fire Fighting Services and are actively engaged in EUROCAE work on this topic. Future guidance for vertiports will include RFFS criteria and additional guidance will be released in due course.

The CAA will further clarify the statement to include the need for a qualified individual to attend the entire process of recharging unless it can be demonstrated that a certified system or appropriate procedure can be used to monitor the process remotely without diminishing safety levels.

Regarding possible divergence from other regulators, while we do learn from outputs of other regulators, we are firmly focused on introducing regulations that are appropriate for the UK environment. We will seek to remain aligned with our international partners, insofar as their approach is suitable for the UK environment.