We Asked, You Said, We Did

Below are some of the issues we have recently consulted on and their outcomes.

We asked

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.

You said

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.

We did

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

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

You said

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 did

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.

We asked

We asked for feedback on the proposal to prohibit instrument flight rules (IFR) flights to be undertaken at supersonic and hypersonic speeds over land (to bring the rules into line with those for visual flight rules (VFR) flights) and to prohibit VFR flights to be undertaken at hypersonic speeds over land without express permission from the CAA.

You said

We received 42 responses in total. Overall, there was support for the proposals which are designed to mitigate the environmental effects on the ground from ‘faster than sound flight.’


The principal areas where respondents considered that there may be negative impact were in efficiency and financial impacts. The concerns centred around aircraft that are designed to be more efficient at supersonic or hypersonic speeds having to fly subsonic over land, therefore impacting on their efficiency and fuel utilisation, potentially leading to greater cost.


A couple of respondents believed there would be a negative impact to safety due to the requirement for these aircraft to “operate in sub optimal flight regimes which could compromise their handling characteristics and thus reduce safety.”  Additionally, another suggested that as “supersonic aircraft are designed to cover long distances at high speed. If they have to reduce to subsonic speed every time they pass over land this manoeuvre, perhaps necessitation [sic] large altitude changes, may be hazardous and would reduce fuel reserves.”


It is important to highlight that it is not the intent for a prohibition of supersonic and hypersonic flight to remain in place for the long term. It is intended to mitigate the environmental effects of ‘faster than sound’ flight and provide protection to those on the ground whilst aircraft are developed that have less of an environmental impact from noise. Moreover, aircraft capable of supersonic and hypersonic speeds will be required to reduce speed at some point during their flight to enable a return to an appropriate approach and landing speed, and their handling characteristics will facilitate this in a safe manner.


One respondent believed that supersonic flight would benefit the air traffic management (ATM) network by getting aircraft to their destination faster, whilst another believed that the additional workload for ATM created by dealing with supersonic flight would offset any benefits of their faster flights. 


Where respondents considered there was a negative impact, this was mainly due to concerns over the inability of developers to conduct flights for research and development (R&D) purposes, especially when those flights were looking to reduce the noise impact of faster than sound flight.  Additionally, there were several concerns over the financial impact should developers of supersonic aircraft look to move away from the UK due to limits being placed on their trial flights.


However, the proposal specifically allows for R&D flights to continue through the power afforded to the competent authority to authorise such flights, whilst still ensuring the protection of people on the ground. It is intended that the proposal to prohibit ‘faster than sound’ flights over land is an interim measure which provides the flexibility to support R&D and the subsequent certification of ‘low-boom’ aircraft.


It is likely that future ‘low-boom’ aircraft will have a far lower noise profile than earlier generations of ‘faster than sound’ aircraft, and thus be much less noticeable to people on the ground. Consequently, they will not need to be limited in the same way as which will allow us to review these requirements accordingly.
 

We did

To facilitate the ongoing development of new aircraft types capable of supersonic and hypersonic speeds, whilst taking into account the impact on citizens on the ground from noise impacts, the Civil Aviation Authority (CAA) will proceed with the task of developing rules which limit when and where aircraft can fly at speeds ‘faster than sound.’


These rules will not affect transonic IFR flight and, where there is a requirement for ‘faster than sound’ flight over land for R&D purposes, the CAA will have power to authorise these where appropriate.


As technology advances and the impacts of ‘faster than sound’ flight on the ground diminish, these rules can be revised to ensure innovative technologies achieve their full potential both in terms of speed and efficiency.
 

We asked

We asked for feedback on the CAA’s position on the adoption of 21 Special Conditions and 2 Means of Compliance, published by the European Aviation Safety Agency (EASA) after the United Kingdom left the European Aviation regulatory system.

You said

We received 5 responses in total. All respondents agreed with the CAA approach to adopt the Special Conditions and Means of Compliance listed in the consultation. There were no comments on the technical content of the Special Conditions or Means of Compliance.

We did

We acknowledge that all respondents supported this proposal, however we are also aware of the limited number of responses. The Special Conditions and Means of Compliance will be adopted and published on the CAA website in due course.

We asked

Between 30 Oct 2023 and 26 Jan 2024, we asked you to comment and form opinions on the proposed UK ISMS regulation which aims to improve cyber resilience in respect of aviation safety. The regulation, firmly based on EASA’s Part-IS, was shared in this form to allow it to be developed, improved, and ensure alignment with the UK aviation market and regulatory structure.

We received 29 responses, made up of a combination of organisations, individuals, and UK aviation industry groups. These responses represent a significant proportion of the industry covering all of the  regulatory areas within the proposed scope of the regulation.

In addition to the core UK ISMS regulation, the consultation requested comments on the associated AMC and GM (Acceptable Mean of Compliance and Guidance Material) which is also based on those documents published by EASA to be used in conjunction with Part-IS.

You said

Responses reflected the variety of challenges faced by each separate industry area which led to some common themes and a wide range of perspectives. One key theme highlighted concerns about over-regulation and how well the requirements will operate in conjunction with existing safety and security regulations. 

Within this, organisations cited the international nature of the industry with many organisations working across borders, and concerns were expressed about how UK ISMS might duplicate similar regulations and requirements outside of the UK, not least for those organisations who are already working towards compliance with Part-IS. 

Some organisations have given us a view of the potential difficulties that would be faced in meeting changes that would impact existing supplier contracts. Noting, reducing the risks around the resilience and security of the supply chain is a priority for all. 

Another key concern raised, was on the proposals around reporting requirements. It was stated that an overly burdensome process for reporting to the regulatory authorities could prevent an organisation from focussing on responding and managing a serious incident, and that opportunities exist within current practices under the current MOR requirements in safety regulation.

Feedback received on the AMC/GM was very much interlinked with the comments on policy and principles within the regulation text, but it was very clear that this document is incredibly important to all organisations and high-quality guidance is needed to support effective implementation and operation of an ISMS. 

Overall, the consultation gave a varied outcome, however it revealed a common want to implement proportionate measures to combat the risks associated to cyber security. 

We did

Analysis of the responses provided to this consultation this will feed directly into our process for preparing the drafting and transposition documents of the rule making process. It is also forming the basis for reflection within our internal working groups across all the CAA. 

Our next steps will be to provide our formal opinion and instruction document to the Department for Transport, in order to commence with this regulatory change.

Work with wider government departments and regulatory bodies on how to fulfil overall ambitions of the proposed regulation, and to align with government ambitions to increase cyber resilience across all sectors.

We will continue to engage with industry stakeholders on the key topics that have been raised in this consultation. 

Work on further detailed supporting and guidance material to supplement the regulation.  

The CAA is committed to transparency and will expand this engagement in due course with the potential for further public consultation.

We asked

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 2024 display season. 

We compiled a draft of CAP 1724 Edition 6 and consulted on it over four working weeks from 20 December 2023 to 19 January 2024. 

You said

We received a total of 35 unique comments to the draft CAP 1724 from 10 respondents.  


Of all the comments, 19 clearly conveyed some sort of change. Of these, 15 comments were textual in nature, suggesting revised wording or highlighting minor drafting points; the remaining 4 comments were more substantive, calling for some sort of change of the underlying policy. 

We did

We accepted 10 of all the comments suggesting some sort of change (53%). 

Of the 15 textual comments received, we accepted 9. Most of these comprised of rewording content for clarification, and we have tried to take a balanced view on what would be helpful. Of the 6 we elected not to implement, some were not specific enough to warrant a change, some suggested changes that were made elsewhere and one requested a change that had already been implemented.

Regarding the 4 more substantive comments we received, we implemented 1. Of those we elected not to implement, one was covered already in this document and it was considered that the remaining comments might have further unintended consequences.

We have produced a final version of CAP 1724 Edition 6 which was published on February 1st 2024. 

We asked

We asked for comments on our proposals for revisions to the existing CAA Charges Schemes, due to take effect from 1 April 2024.

You said

We received 128 submissions from 37 respondents.

We did

Full details have been published in our consultation response document.

We asked

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 2024 display season. 

We compiled a draft of CAP 403 Edition 21 and consulted on it over four working weeks from 27 November 2023 to 22 December 2023. 

You said

We received a total of 32 unique comments to the draft CAP 403 from 12 respondents.  


Of all the comments, 26 clearly conveyed some sort of change. Of these, 20 comments were textual in nature, suggesting revised wording or highlighting minor drafting points.

Many of these comments were duplicated between respondents; and the other 6 comments were more substantive, calling for some sort of change of the underlying policy. 

We did

We accepted 16 of all the comments suggesting some sort of change (62%). 

Of the 20 textual comments received, we accepted 15. Most of these comprised of rewording content for clarification, and we have tried to take a balanced view on what would be helpful. Of the 5 we elected not to implement, some were not specific enough to warrant a change, some suggested changes that were made elsewhere and it was considered that the remainder might have further unintended consequences.

Regarding the 6 more substantive comments we received, we implemented 1. Of those we elected not to implement, some were beyond the scope of CAP403, others were covered adequately either in this document or elsewhere, and it was considered that the remaining comment might have further unintended consequences.

We have produced a final version of CAP 403 Edition 21 which was published on February 1st 2024. 

We asked

This consultation document (CAP2601) concentrated solely on the advertising element of the proposed changes to the cost sharing rules. As our proposals on advertising were created as a result of responses received during our first consultation and differed significantly from the original proposal, the public had not been offered the opportunity to comment on the changes we suggested.

Furthermore, since we published our initial proposals, further proposals have been suggested as part of concurrent CAA projects looking at GA licencing and Pilot Medical Declarations (PMD).

We therefore decided to provide the GA community with this additional opportunity to input their views on the advertising of cost sharing flights through this additional consultation before the policy is finalised.

You said

We received 1817 individual responses to our consultation questions, with 575 additional comments. The results are summarised below:

Q1: Do you currently or have you ever advertised a cost sharing flight online?

  • Yes 11.72 %
  • No 83.32 %
  • Prefer not to say / not answered 4.95 %

Q2: Do you agree that the advertising element of the current cost sharing regulations should be reviewed and amended?

  • Yes 21.19 %
  • No 77.22 %
  • Prefer not to say / not answered 1.60 %

Q3: Prior to the UK joining EASA, the advertising of a cost sharing flight was prohibited outside of a flying club environment. Would you support a return to those requirements regarding the advertising of cost sharing flights?

This required that: "no information has been published or advertised before the commencement of the flight other than, in the case of an aircraft operated by a flying club, advertising wholly within the premises of such a flying club in which case all the persons carried on such a flight who are aged 18 years or over must be members of that flying club". 

  • Yes    13.65 %
  • No    85.25 %
  • Prefer not to say / not answered    1.10 %

Q4: In relation to the proposed amendments: "Cost sharing flights may be advertised. The advertisement must be placed by the pilot intending to operate the flight and it must relate to a specific flight that the pilot intends to take place, regardless of whether passengers are available for carriage. The advertisement must include the start and end locations, as well as the dates when the pilot intends to conduct the flight." To what extent do you agree that this proposed amendment is clear and easy to follow?

  • Strongly agree 14.64 %
  • Agree 9.74 %
  • Neither agree nor disagree 4.51 %
  • Disagree 8.37 %
  • Strongly disagree 62.74 %
  • Not answered 0 %

Q5: In relation to the below proposed amendments: "Cost sharing flights may be advertised. The advertisement must be placed by the pilot intending to operate the flight and it must relate to a specific flight that the pilot intends to take place, regardless of whether passengers are available for carriage. The advertisement must include the start and end locations, as well as the dates when the pilot intends to conduct the flight." To what extent do you agree that this proposed amendment is appropriate?

  • Strongly agree 13.48 %
  • Agree 8.31 %
  • Neither agree nor disagree 3.25 %
  • Disagree 8.37 %
  • Strongly disagree 66.59 %
  • Not answered 0 %

Q6: Do you believe that a pilot should have to include any of the following information in their advertisement to ensure passengers are fully aware of a pilot’s credentials before booking to join a cost sharing flight? (Please select all that apply)

  • Licence type held (i.e. PPL) 87.62 %
  • Medical held (i.e. Class 2, PMD) 79.09 %
  • Flying experience 85.20 %
  • Pilot recency 75.95 %
  • None of the above 6.71 %
  • No opinion / don’t know / not answered 3.74 %

Of the 575 additional comments received, all were analysed, and some main themes were identified. These included:

  • The proposed amendment to advertising goes against the assumed original intent of cost sharing (i.e. hour building, maintaining currency, introducing more people to GA, allows for cheaper flying costs)
  • There needs to be more flexibility in the advertising of cost sharing flights
  • There needs to be better monitoring of cost sharing flights by the CAA
  • Cost sharing flights should not be available online / to the general public
  • Pilots / third parties should not be able to make a profit for cost sharing flights
  • Cost sharing flights are detrimental to commercial organisations 

We did

We have concluded the analysis of all responses received and have taken into account stakeholder feedback on this topic. We are grateful for the submissions received and acknowledge that the majority of stakeholders who responded are against our proposed changes to the advertising element of the cost sharing regulations. 

With that in mind, and after having completed further internal work to review the safety concerns relating to cost sharing flights, we have decided to revise our final policy position and will be providing our formal opinion to the Department of Transport (DfT) shortly. This formal opinion will include all other changes confirmed in CAP 2391 which we previously consulted on. 

With regards to the advertising of cost sharing flights, our proposed changes to the regulation will be as follows, (please note the below is not the final regulation wording, the DfT are responsible for the final wording of the regulation):  
Cost sharing flights may be advertised. The advertisement must be placed by the pilot intending to operate the flight and must include the start and end locations, the date when the pilot is available to conduct the flight, and any other information prescribed by the CAA.

We will also publish Guidance Material (GM), CAP documents, Acceptable Means of Compliance (AMC)  and if applicable Alternative Means of Compliance (AltMoC) which will provide pilots and the public with further information about cost sharing flights including, but not limited to, that it is understood that pilots may choose to change the advertised destination at any point for any reason such as weather etc but passengers should not be permitted to dictate the destination of the cost sharing flight in the manner of someone chartering an aircraft. 

Taking into account the stakeholder feedback received, we understand that cost sharing flights need to have a certain amount of flexibility and therefore we feel that this revised wording allows for that whilst still ensuring that the pilot is in full control of the destination and date/time of the flight.

Our main objectives when reviewing the existing cost sharing regulations were to improve the regulation and guidance to ensure potential passengers better understand the type of flight and risks involved, and to help pilots better understand the regulation. We believe that we have achieved these objectives with the changes we are proposing to introduce, and therefore accept that allowing some flexibility in the advertising of cost sharing flights would not significantly impact the safety of such flights.

During the consultation we asked the community whether any additional information relating to the pilot’s credentials such as licence, medical held etc, should be included in any advertisement of a cost sharing flight. We are still reviewing this element of the proposal at this time. 

The internal working group are considering whether this information would be adequately understood by members of the public and a decision on what should be included will be made in due course. Therefore, we have chosen to include in the proposed regulation wording a statement which will allow for this: ‘and any other information prescribed by the CAA’. 

We believe this requirement will allow the CAA to require the disclosure in advertisements of additional information considered important to assist passengers to make an informed decision whether to take a particular flight. It will also enable the CAA to require disclosure of additional information that becomes relevant to potential passengers as a result of developments in future technologies.

The CAA will now finalise the revised policy proposal to the DfT and will collaborate with relevant stakeholders to produce the supporting documentation to enable a regulation amendment. Until these changes come into effect, the cost sharing regulations remain as they are currently and there is no immediate action for the community to take.

We asked

We asked for feedback on the CAA’s approach to type-certification of VTOL aircraft. The CAA policy statement aims at highlighting the approach to type-certification for VTOL aircraft for those seeking to type-certify their aircraft in the UK while the CAA learns more about this type of aircraft, its capabilities, and type of operations they will undertake.

You said

We received 5 responses in total. There was overall support for the approach taken. One respondent wanted to understand if the same principles will apply to certification standards for propellers (CS-P) and engines (CS-E).

Two respondents wanted closer cooperation and alignment with CAA’s international counterparts to expedite approval of VTOLs. One respondent suggested the CAA adopts future EASA Means of Compliance, in consultation with industry, to achieve regulatory alignment.

One respondent asked the CAA to ensure regulations evolve as capabilities of VTOLs and types of operations they participate in evolve as well. Finally, a respondent suggested expanding the description on VTOL to include all aircraft capable of vertical take-off and landing, both with on-board pilot and remotely piloted ones.

We did

We acknowledge that stakeholders were broadly supportive or not against the proposed policy position.

The CAA continues to work very closely with its counterparts around the world, to share knowledge and learn from best practices.  We seek to enable swift introduction of VTOL to the UK market and appreciate the importance of international harmonisation, while maintaining appropriate safety standards for the UK.

We confirm that Certification Specifications for Propellers (CS-P) do apply to propellers used by VTOL. With regard to motors, the CAA is working on developing certification standards specifically for electric motors and will publish the draft standards in the near future.

Regarding EASA’s future Means of Compliance, 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 that approach meets the priorities of the UK.

We do not believe it is appropriate to describe VTOL in a way that would include all aircraft capable of vertical take-off and landing. VTOL have a number of unique features, such as number of thrust/lift units and control systems, that necessitates to treat them as a separate group of aircraft.

Treating them as part of existing categories would not sufficiently account for those differences. Regarding expanding the definition to include remotely piloted aircraft, remotely piloted aircraft in the certified category are already subject to UK regulations.

We remain committed to flexibility in the face of an evolving VTOL market. As the technology evolves, and in consultation with industry, we will work to maintain a proportionate approach to the regulatory framework and meet the needs of the UK aviation industry, without compromising on safety standards.

We asked

We asked for feedback on the CAA’s position on requirements for piloted Vertical Take Off and Landing (VTOL) capable aircraft pilots wishing to perform commercial air transport (CAT) operations.

You said

We received a total of 9 responses. Most respondents were in favour of the proposal to regulate VTOL using existing rules, but there was an interest in seeing timelines for introducing an ab initio pilot licensing regime, and additional policy positions on vertiport and air navigation service providers (ANSP).

Two respondents noted the lack of guidance for licensing of pilots undertaking non-commercial flights. One respondent was concerned that the statement’s principles will apply to non-commercial VTOL pilots as well. One respondent argued experience with flying VTOL should be first gained through non-commercial flights.

One respondent advocated broader use of Flight Simulation Training Devices for Zero Flight Time Training, Line Flying Under Supervision, and skill tests. One respondent suggested IFR pathway should be type specific.

A respondent wanted to know if dual controls will be required for completion of pilot training and if pilots will have to have an instrument rating; and asked about requirements for training hours and cross-country flying requirements.

One responded called for a licensing framework tailored separately to piloted, remote, and uncrewed flight operations.

We did

We acknowledge that respondents broadly supported the proposed approach. There was a notable call for more flexible means for training pilots and guidance on non-commercial operations using VTOL.

We reiterate that this policy position concerns only pilots that seek to perform Commercial Air Transport operations in a VTOL aircraft and does not suggest the same principles will apply to non-commercial operations.

We also acknowledge that a statement of a similar nature on principles applicable to non-commercial operations using VTOL would benefit the industry and will seek to develop this in due course.

We acknowledge that starting in non-commercial operations using VTOL to gain experience before progressing to commercial operations is a valid path for pilots. However, requirements for training and assessment will ensure that pilots holding a commercial pilot licence will meet appropriate standards before they undertake any passenger or cargo carrying operations in a VTOL aircraft.

The CAA is developing its thinking on Zero Flight Time Training (ZFTT), higher utilisation of Flight Simulation Training Devices (FSTD) and training in single-control VTOL aircraft.  The CAA welcomes input from industry to help establish how these approaches could be effectively used for training single-control VTOL aircraft pilots.

Regarding instrument ratings, we note that requirements will depend on the type of operation being performed. We will be using FCL.720.PL as a basis for the initial requirements before commencing a type rating course.

However, our current thinking is that it needs to be adjusted so that there will only be a requirement for an Instrument Rating (IR) where the operational case of the aircraft requires one, in line with current aviation practice.

There are no cross-country requirements in a type rating. Cross country experience would have been gained through the pilot licensing process. Training hours are determined as part of the Operational Suitability Data (OSD) process, which is part of the overall aircraft certification process that the aircraft manufacturer will complete.

If no training hours are present in the OSD, then the minimum training hours contained in the Acceptable Means of Compliance to the Assimilated Regulation (EU) No. 1178/2011 will apply.

Regarding creating separate frameworks for piloted, remotely piloted, and uncrewed operations, this policy statement focuses specifically on initial commercial operations using piloted eVTOL. Remotely piloted aircraft in the certified category covers operations that present an equivalent risk to that of manned aviation.

Because of this they are be subjected to the same regulatory regime (i.e. certification of the unmanned aircraft, certification of the operator, licensing of the pilot). UK regulations relating to the certified category are still being developed and are not yet published. Until unique regulations are available, the principles set out in the relevant manned aviation regulations for airworthiness, operations and licensing will be used as the basis for regulating the certified category. Further information can be found in CAP 722.

We appreciate that the industry would like to see specific timelines for the work we are doing, including a timeline for an ab initio pilot licensing path.   We are developing our thinking while collaborating with international partners, and will share information, including estimated timelines, when available.

We remain committed to the overall target of enabling commercial VTOL operations by 2026. We also continue to engage with industry on an ongoing basis to discuss our overall thinking and policy aims.  You can find further information on our ongoing work and outputs on the CAA’s Innovation Hub.

We asked

We asked for feedback on the CAA’s position on commercial flight operations using VTOL aircraft.

You said

We received 14 responses in total. Multiple respondents asked for timelines for when the interim guidance will be replaced with new or amended regulations. Several respondents called for closer collaboration with the industry and a level of harmonisation with other authorities.

One respondent suggested regulations should be reviewed to account for the introduction of VTOLs. Another respondent suggested that the proposed conversion training would not account for the low-altitude nature of VTOL operations and the locations where they will take place (such as urban environment).

A respondent noted that Rescue and Fire Fighting Services (RFFS) provisions do not sufficiently account for the use of lithium batteries by VTOL and the potential hazards associated with firefighting lithium fires and should therefore be reviewed. One respondent suggested the CAA should work on alternative means of compliance for aircraft unable to fully meet current requirements.

One respondent noted that while the paper is about CAT operations, it also mentions non-commercial operations as well, producing confusion on the scope of the paper. It also lacked rationale for treating VTOL as Complex Motor-Powered Aircraft (CMPA).

Several responses highlighted the lack of detail in the paper on issues such as energy reserve requirements, alternate landing sites/diversions, visibility limits, and other operational elements. There was also an overall preference to maintain operational parity with helicopters.

One respondent suggested current operations rules will not support meaningful commercial eVTOL services and EASA operations rules should be the basis for UK-specific regulation.

One respondent asked for better articulation on how existing rules apply to VTOLs, especially in the context of transition from vertical to horizontal flight.

We did

We are giving all comments due consideration to ensure VTOLs are regulated in an appropriate manner relative to the risk.

To this end, we remain in close contact with the industry to collect their views and suggestions and have undertaken a detailed analysis of all applicable current UK regulations and other countries’ proposed rules. The CAA is committed to the Future of Flight timelines and work is underway to draft revised flight operations rules. Industry input will be solicited. However, no specific timelines can be given at this time on when the regulations will be amended as elements of the changes are outside of our control.

We note that the conversion training mentioned in the policy statement does not replace any additional training that may be necessary to perform certain operations, eg. low-altitude, in specific locations or weather conditions. Conversion training is only intended to assist in enabling a pilot to fly different types of aircraft than the ones they were trained on.

We are aware of the challenges posed by lithium 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.

We point out that the paragraph referring to non-commercial operations was only intended to highlight that cost-sharing flights using VTOL are not permitted. We are currently of the view it is appropriate to treat VTOL as complex motor-powered aircraft because of their novel nature, and broad differences in their constructions and operational performance. This prohibits cost-sharing flights using VTOL aircraft.

Regarding using EASA’s regulations as a basis, 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 it meets the priorities of the UK.

We are also aware that there are other areas of operations policy that will require clarification, including energy reserve requirements and visibility. We are in the process of reviewing all areas of the operations regulations to ensure they are appropriate for VTOLs and their operations, and further consultation in the form of working groups will be established.

You can find further information on our ongoing work and outputs on the CAA’s Innovation Hub.

We asked

We asked for feedback on the CAA’s position on the continued airworthiness regulatory basis applicable to VTOL aircraft.

You said

We received 4 responses in total. One responder left no comment. Three respondents welcomed the approach. One respondent noted that an increase in complex motor-powered aircraft may put more strain on CAA’s resources, therefore adequate funding for regulatory oversight is important.

We did

We acknowledge that respondents were broadly supportive of the approach, but are also aware of the limited number of responses. With regards to funding comments, the CAA reviews its capabilities on an ongoing basis and remains confident it is in a strong position to deliver appropriate oversight.

We asked

The purpose of the consultation was to seek stakeholders’ views on adoption of a policy to simplify the process for the adoption of harmonised product design related Certification Specifications. The process will enable stakeholders to make use of new and updated Certification Specifications without undue delay.

You said

We received twenty-seven individual responses to our consultation. Twenty-five respondents fully supported the proposed approach. Two respondents did not fully support the proposal, one cited the need for greater involvement of the CAA and UK stakeholders in the CS development process. The other respondent supported the adoption of new and revised EASA CS but wanted the opportunity to make representations to the CAA on each proposed amendment prior to adoption.

Several respondents proposed extending the scope of the proposed policy to include Certification Specifications used outside the initial airworthiness domain. Other comments included proposals for including Special Conditions and Certification Memos in the scope of the new policy.

Several respondents also asked if the CAA could further expedite the CS adoption process as the current approach disadvantages British business who want to produce designs conforming to the latest specifications.

We did

We acknowledge that stakeholders strongly support the proposed changes. There is a clear view that expediting the adoption of EASA Certification Specifications is in the best interests of businesses in the UK.

We note the comments that seek to extend the scope of the policy to Special Conditions and to CS applicable outside the initial airworthiness domain. We have decided not to include these additional areas in the scope of the new policy until we have gained some experience of implementing the new policy. Of the comments that did not fully support the proposal, we note the desire to increase the involvement of the CAA in the development of internationally harmonised standards. The CAA will endeavour to increase UK involvement as our design capability grows. Regarding the remaining comment, the CAA will not be taking forward the proposal to systematically consult on each new or amended CS. This would inevitably extend the time taken to adopt changes and potentially undermine the main objective of the proposal to increase competitiveness of businesses in the UK through reducing the time it takes to adopt new and revised EASA CS.

The CAA will now finalise the revised policy and will publish a new Decision in Official Record Series 9, adopting the latest versions of the EASA derived design related Certification Specifications.

We asked

The purpose of this consultation was to share the CAA’s proposal for the future of remote pilot (RP) competency in the specific category.

The proposal covered:

  • Rulemaking to establish RAEs under an improved legal basis such as the UK Regulation (EU) 2018/1139, the Basic Regulation
  • Establishing medical standards for RPs in the specific category 
  • Developing a framework for the future of RP competency 
  • Developing the supporting RP competency policy, AMC, and GM 

You said

We received 112 responses. Most responses (66%) were received from UAS operators and remote pilots.

The CAA reviewed all the comments received, and the following trends were identified:

  • The CAA should consider retaining the GVC and/or introducing another form of entry level VLOS qualification.
  • The naming convention of the two proposed certificates is confusing and should be reviewed.
  • The subject matter of the RPC-B is too broad the CAA should consider splitting the VLOS and BVLOS elements.
  • The CAA should continue with the GVC bolt-on systems that was previously proposed. 

In addition to the above, the CAA received feedback welcoming the recognition that BVLOS training for RPs is an important enabler for industry. We also received positive feedback on the thoroughness of the work carried on the RPC-A from operators already conducting complex BVLOS operations. 

We did

In parallel to the phase one consultation, the CAA policy team has continued to engage with industry and RAEs through direct outreach and stakeholder meetings.

The CAA will publish a proposed update to the AMC and GM to Article 8 of the UK Regulation (EU) 2019/947 including multiples changes to the RPC framework as a direct result of the phase one consultation feedback. This full public consultation will run for 12 weeks and expected to commence in Q4 2023.

We asked

The CAA consulted on an interim arrangement to continue to require ANSPs to provide documented evidence to demonstrate compliance with regulations and means of compliance associated with Air Traffic Services systems and constituents. The CAA proposed to update CAP 670 ‘Air Traffic Services Safety Requirements’ with a new section requesting ANSPs to provide this evidence.

You said

The CAA received one response to the consultation, with 5 comments.  The respondent did not request changes to the proposed means of compliance to be published in the CAP but requested further guidance to provide clarity and enable compliance, and proposed changes to the associated template forms.

We did

The CAA has published a Consultation Response Document that sets out each comment and includes our response. The guidance and template forms have been updated and the change to the CAP has been initially published as a Supplementary Amendment.

In the longer term the CAA will establish a new Regulatory Framework for the demonstration of compliance and approval/certification of ATS system and constituents, which will be subject to further consultation.

We asked

The purpose of the consultation was to seek views on defining the scope of the environmental assessments for the airspace change masterplan, and the way we will approach carrying them out, including the methodology. We were not consulting on the masterplan itself, the individual airspace change proposals that make up the masterplan, or the environmental assessments themselves.

Please see “Overview” below for more information.

You said

We received 18 responses to the consultation. We have published all 18 responses, but some respondents chose to remain anonymous.

You can download responses, where we have permission to publish them:
(a)
here, for responses submitted through this consultation website
(b) by following the links at the bottom of this page, for responses submitted off-line.

We received responses from:

Statutory Nature Conservation Bodies (7): Joint Nature Conservation Council, Natural England, Environment Agency, Historic England, Scottish Environment Protection Agency, Nature Scot, Historic Environment Scotland

National organisations (1): Aviation Environment Federation

Airports (3): All preferred to remain anonymous

Residents affected by aviation (3): All preferred to remain anonymous

Organisations with an interest in a specific airport or location (4): Communities Against Gatwick Noise & Emissions (CAGNE), Heathrow Strategic Planning Group, Stansted Airport Watch, The Royal Parks

The consultation questions asked for a mixture of multiple-choice and free-text responses. These are summarised in the tables below.

(1)  Answers to multiple-choice questions

SEA Scoping Report

Number of responses

Questions 1 to 6 were about the Strategic Environmental Assessment (SEA) Scoping Report www.caa.co.uk/cap2526

Yes

No

Don’t know / did not answer

Q1: Are you satisfied with the environmental aspects we have scoped out and in of the SEA, and the objectives, targets and indicators?

7

4

1 / 6

Q2 Are you satisfied with how any significant effects will be identified?

6

4

2 / 6

Q3 Are you satisfied with the definition of the future baseline, assessment case and alternatives?

6*

3

3 / 6

Q4 Are you satisfied with the proposed Zones of Influence for each environmental aspect?

4

7

1 / 6

Q5 Do you have any comments about the type and use of available regional data for each geographical ‘cluster’?

 

These questions were free-text only

Q6 Do you have any other points you would like to raise in relation to the SEA Scoping Report?

 

                                                                                                                  *2 were a qualified yes

HRA Screening Report

Number of responses

Questions 7 to 12 were about the Habitats Regulations (HRA) Screening Report www.caa.co.uk/cap2527

Yes

No

Don’t know / did not answer

Q7 Are you satisfied that the HRA Screening Report correctly identifies all potential significant effects on European Sites?

5

2

5 / 6

Q8 Are the precautionary ZoIs applied to each potential effect to determine which European sites may be affected by the implementation of the masterplan appropriate for the purposes of screening?
 

4

5

3 / 6

 

Is about right

Requires minor mods

Requires major mods

Don’t know /
did not answer

Q9 Do you consider that the CAA’s proposed approach to applying the scientific evidence referenced in appendices B, C and D of the HRA Screening Report to stage 2 of the assessment is appropriate?

4

0

1

7 / 6

Q10 Do you consider that the CAA’s proposed approach to subsequent stages (2, 3 and 4) of the Habitats Regulations assessment:

4

1

 

7 / 6

Q11 Which plans and projects do you think might act in combination with the masterplan?

 

These questions were free-text only

Q12 Do you have any other points you would like to raise in relation to the HRA Scoping Report?

 

Approach to SEA and HRA

Number of responses

Questions 13 to 15 (SEA) and questions 16 to 18 (HRA) below were about the approach we propose to take when producing the actual environmental assessments/reports themselves, later on. This proposed approach is set out in the Approach to SEA and HRA document www.caa.co.uk/cap2528

Yes

No

Don’t know / did not answer

Q13 Are you satisfied that the overall approach to SEA (set out in paragraph 1 of the 'Approach' document) will ensure that the environmental effects of the masterplan are fully assessed?

7

5

0 / 6

Q14 Do you have any comments on the timing of the SEA (stages 1.B – 1.F and Figure 1 in the 'Approach' document) during the development of each masterplan Iteration?

 


These questions were free-text only

Q15 Do you have any other comments you would like to make on the approach to SEA of the masterplan (set out in paragraph 1 and Figure 1 of the ‘Approach’ document)?

Q16 Do you agree that it is not possible to rule out significant effects on European sites (or offshore marine sites) as a result of the masterplan? (paragraph 2.A of the ‘Approach’ document)

6

0

6 / 6

Q17 Do you have any comments on the intention to deliver any required mitigation for adverse effects on the integrity of European sites (or offshore marine sites) at the project level, through the approval process for individual airspace change proposals - rather than at the strategic level through the masterplan? (paragraph 2.C of the ‘Approach’ document)

 

 

 

These questions were free-text only

Q18 Do you have any other comments you would like to make on the approach to HRA of the masterplan (set out in paragraph 2 and Figure 1 of the ‘Approach’ document)?

 

(2)  Answers to free-text questions

The table below shows the themes that were identified from the free-text responses, the main issues that were raised, and how many times.

Summary of free-text responses to the HRA consultation 

Theme

Main issues raised
under this theme

Total number of issues within the theme

Total number of responses mentioning this theme

Protected sites

 

Definitions; scope

3

2

Impacts

 

Various pollutants including NH3, NOx, SO2 ; bird disturbance; cumulative impacts

6

4

Zones of Influence

Definitions; impact risk zones

2

3

In-combination assessment

Road transport; marine environment; land-use planning for airport expansion

3

4

Mitigation

Measures at the level of individual airspace change proposals

1

1

Approach to HRA

Five stages of assessment; imperative reasons of overriding public interest; assessment of the London TMA cluster; air traffic growth; airfield boundary changes

7

4

 

Summary of free-text responses to the SEA consultation 

Theme

Main issues raised
under this theme

Total number of issues within the theme

Total number of responses mentioning this theme

Receptors

Additional areas or matters for consideration; local community impacts

6

5

Impacts

Various pollutants including NH3, NOx, SO2 , ozone, particulates; listed buildings and protected landscapes; visual impact; social intrusion; tranquility; aircraft collisions; vibration; equity and levelling-up; equality impact assessment; unintended consequences of decarbonisation; DfT noise policy; local air quality management regime; human health; cumulative impacts

20

11

Screening thresholds

Definitions

2

1

Zones of Influence

Definitions and methodology; impact risk zones; noise concentration

8

8

Alternatives

Assessment of alternatives; iterative approach to masterplan

2

2

Approach to SEA / miscellaneous

Terminology; references; policy framework; assessment of the London TMA cluster; consultation and engagement; assessment of economic benefits and airspace efficiency vs environmental impacts; efficacy of legislative and policy measures; performance-based navigation; crops for sustainable aviation fuel; Gatwick expansion; land-use planning for airport expansion; air traffic growth; impacts of General Aviation; legal challenge to Jet Zero Strategy

17

10

We did

We are taking into account responses to this consultation in developing the environmental assessments for the airspace change masterplan. We expect to consult on the first of those assessments in 2024.

Please see “Overview” below for more information.

We asked

The purpose of the consultation was to seek your comments on proposed Means of Compliance & Guidance in support of UK Special Condition SC-VTOL, for the certification of electric vertical take-off and landing aircraft.

You said

There was clear support for adoption of the proposed MOC and guidance. Commenters recognised that the material is consistent with that introduced by EASA and that this will benefit UK industry by reducing safety barriers for export to the EU. Respondents also supported the continuation of harmonisation efforts with the USA.

One respondent provided a variety of editorial and technical comments against the material, these were mainly additional to comments that had previously been made by the respondent organisation to EASA, during its consultation process for the MOC in 2020 and 2021.

As MOC to a Special Condition, the published content is not binding. It is a way, but not the only way to show compliance to SC-VTOL. It is therefore possible for an applicant for certification to propose an alternative MOC; provided that this enables a satisfactory demonstration of compliance to the safety objective within SC-VTOL itself. With this broader context in mind, when we reviewed the above comments, we determined that some were of a general nature, while others reflected developing experience with a particular aircraft design. It is also recognised that as a new aviation sector, eVTOL designs are varied and continue to evolve. As such SC-VTOL and the associated MOC are a starting point, and these will evolve with experience from industry and the regulators. We consider that the best way forward, in order to support the over-arching objective of harmonisation with both FAA and EASA, is to retain the MOC text as published and to bring these insights into conversations with other regulators, as we learn through undertaking certification programmes.

There was no objection to the proposed Means of Compliance & Guidance in support of UK Special Condition SC-VTOL, for the certification of electric vertical take-off and landing aircraft.

We did

We are grateful for the submissions received, we have reviewed each comment and provided feedback to respondents as appropriate.

As described above the consensus from respondents was in support of adoption and implementation of the referenced MOC, and of CAA’s continued efforts toward harmonisation with FAA and EASA for this new aviation sector. Where changes to the published material were proposed, and recognising that CAA is committed to evolving SC-VTOL based on experience across both industry and other regulators; it has been decided that these should be addressed either within the broader frame of harmonisation or where appropriate, through consideration of alternative MOC within the certification process.

Note: At the time we published our MOC adoption proposal, the document MOC-3 SC.VTOL Issue 1, had completed EASA Open Consultation, and was in their Comment Response (CRD) process. This has been finalised and Issue 2 was published by EASA on 21 June 2023. We have reviewed issue 2 of the EASA MOC (and CRD) and consider the finalised version to be acceptable to CAA. We have also reviewed it against comments submitted to CAA in response to our MOC adoption proposal. The commenter has confirmed that their comments made to both CAA and EASA, have been satisfactorily resolved by EASA in their final version, Issue 2.

We will proceed to adopt the Means of Compliance & Guidance in support of UK Special Condition SC-VTOL, for the certification of electric vertical take-off and landing aircraft.

We asked

Between 5 January 2023 to 19 March 2023, we asked for your views on proposals for a new version of the Airspace Change Process Guidance, known as CAP 1616.

We suggested proposals on:

  • The structure of CAP 1616
  • Scaling and the baseline in the process
  • Stages, steps and gateways 
  • Engagement, consultation and communications arrangements/processes
  • Clarity of the process and the document
  • Instrument Flight Procedures (IFP)
  • Temporary Airspace Changes/Airspace Trials

You said

106 responses were received in total. You can read the full report by visiting our website: www.caa.co.uk/CAP2567

High level headlines of the consultation feedback received can be found in the Executive Summary of the full report.

We provide detailed analysis of quantitative and qualitative feedback within Chapter 3 of the full report.

Please also see the answers to questions that were not responded to in the Questions and Answers session from 9 February 2023 in this document.

We did

Taking into account stakeholder feedback, we will be progressing a package of changes that will focus on providing simplification, clarification and proportionality. The package of improvements involves multiple strands and some of these will take longer to develop and deliver.  While our priority will be to develop and publish a new suite of CAP 1616 documents, we will also do more to educate and inform stakeholders about the requirements of the CAP 1616 Airspace Change Process.

The key actions from the consultation can be found in the Executive Summary of the main report. 

Rationale and explanation for all actions we are taking are detailed in Chapter 3 of the main report.

Next Steps

We will produce and publish a revised version (V.5) of CAP 1616, and we will work with Change Sponsors to help them understand what the changes mean for their Airspace Change Proposal, if any. Notification of publication will be provided to our stakeholders via our dedicated review webpage and associated media/communication channels.

We asked

We asked for feedback from the regulated community on proposed amendments to CAP 1724 ahead of the 2023 display season. 

We compiled a draft of CAP 1724 Edition 5 and consulted on it over four working weeks from 13 February 2023 to 10 March 2023. 

You said

We received a total of 20 unique comments to the draft CAP 1724 from nine respondents.  

Of all the comments, fourteen clearly conveyed some sort of change. Of these, eleven comments were textual in nature, suggesting revised wording or highlighting minor drafting points. Some of these comments were duplicated between respondents; and the other three comments were more substantive, suggesting changes of the underlying policy. 

We did

We accepted four of all the comments suggesting some sort of change (29%). 

Of the eleven textual comments received, we accepted four. Most of these comprised of rewording content for clarification, and we have tried to take a balanced view on what would be helpful. Of the seven we elected not to implement, five called for revisions to the text that we had carefully drafted in cooperation with other organisations, one suggested changes that have already been made, and it was considered that the remaining suggestion would not contribute to the document.

Regarding the three more substantive comments we received, none were implemented. Two of these reflected on material that we thought was covered adequately either in this document or elsewhere. The remaining comment suggested a change to existing text that had been written after extensive consultation with the community.

We have published a final version of CAP 1724 Edition 5 which was published on 6 April 2023.