We Asked, You Said, We Did

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.

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 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.

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 

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. 

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.

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.

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

(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 

Summary of free-text responses to the SEA consultation 

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.

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.

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 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.

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

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.

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 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. 

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 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. 

We asked for feedback from the regulated community on proposed amendments to CAP 403 ahead of the 2023 display season. 

We compiled a draft of CAP 403 Edition 20 and consulted on it over four working weeks from 30 January 2023 to 24 February 2023. 

We received a total of 55 unique comments to the draft CAP 403 from 21 respondents.  

Of all the comments, 33 clearly conveyed some sort of change. Of these, 22 comments were textual in nature, suggesting revised wording or highlighting minor drafting points. Many of these comments were duplicated between respondents; and the other 11 comments were more substantive, calling for some sort of change of the underlying policy. 

We accepted 12 of all the comments suggesting some sort of change (36%). 

Of the 22 textual comments received, we accepted 8. 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 14 we elected not to implement, some called for revision to text that we had carefully drafted in cooperation with other organisations, some suggested changes that have already been made, whilst it was considered that the remainder might have further unintended consequences.

Regarding the 11 more substantive comments we received, we implemented 4. Of those we elected not to implement, all bar one asked that we expand on material that we thought was covered adequately either in this document or elsewhere. It was considered that the remaining comment might have further unintended consequences.

We published Edition 20 of CAP 403 Flying Displays and Special Events: Safety and Administrative Requirements and Guidance.

We asked for comments on the proposals for new Acceptable Means of Compliance (AMC) and Guidance Material (GM) relating to the changes made to UK Regulation (EU) 965/2012 (the Air Operations Regulation) by the Aviation Safety (Amendment) (No. 3) Regulations 2021/1203. Regulations 7-11 introduce requirements relating to the detection and prevention of misuse of psychoactive substances and the creation of support programmes. The AMC and GM proposed for: 

• The UK Civil Aviation Authority (CAA) to conduct ramp inspections which include arrangements for alcohol testing. 
• Commercial Air Transport (CAT) operators to develop a policy on the prevention and detection of misuse of psychoactive substances. 
• CAT operators to facilitate access to a proactive and non-punitive support programme for flight crew members to assist those persons to recognise, cope with and overcome any problem which could negatively affect their ability to safely exercise the privileges of their licence.

We received 29 comments from 8 respondents.

Your responses generally agreed with the proposed changes. Your comments included the following:

• Testing should be conducted in such a way as to promote an amicable, non-confrontational atmosphere with a view to preserving the mental and emotional well-being of the crew members concerned, as well as advancing the priority of maintaining flight safety.
• A request for clarification on an 'appropriate and approved' device and 'national requirements’.
• Specific details on the initial and recurrent training of ramp inspectors with regards to alcohol testing.
• An operator should establish an appeal process with regards to psychoactive substances.
• Endorsing the proposed material to enable operators to effectively implement support programmes to assist crews with welfare issues.

You also commented on the potential regulatory burden on small operators implementing the AMC/GM with regards to psychoactive substances and support programmes.

You said that support programmes should be available to all safety sensitive personnel.

The Air Operations Regulation has contained requirements for the development and implementation of policies on the prevention and detection of misuse of psychoactive substances and the creation of a support programmes for all operators since November 2021. We have developed clear and accessible AMC and supporting GM to these regulations, which outlines:  

• Operator responsibilities for the development and implementation of a policy and associated procedures for the prevention and detection of misuse of psychoactive substances by crew members and other safety-sensitive personnel.
• Flexibility in the approach to the method of testing to ensure the requirements are proportionate to the size of the organisation.
• How an operator should meet its requirements to provide a support programme for flight crew.
• Operator responsibilities for the prevention of a person boarding an aircraft when under the influence of a psychoactive substance and behaving in such a way as to endanger safety.

The AMC and GM were developed with due consideration to the UK industry and our own established reporting processes. Following consultation, the CAA has also carried out a thorough review of all the comments received and made amendments where we feel further clarification is required. For example, we have included in the AMC that operators should provide for an internal appeal process following a confirmed positive test result.

In response to the comments received we have made some adjustments to provide additional clarity on the training of ramp inspectors, and agreed to update the procedure for the conduct of alcohol testing during ramp inspections to help preserve crew wellbeing as far as is practically possible.  

Safety is of paramount importance to the CAA and underpins all our decision-making. At the same time, we acknowledge the potential additional burden, particularly for smaller organisations, to conduct pre-employment alcohol testing and ongoing random testing. Therefore, we have left the frequency of ongoing testing to individual organisations to determine based on their size and complexity of their operation.

 As per the requirement of ARO.RAMP.106 (b), we have established procedures for ramp inspections which are contained in the Ramp Inspectors Manual). The purpose of this manual is to describe best practices and give guidance to the CAA personnel performing ramp inspections including alcohol testing. It covers the delivery, management, and administration of ramp inspections as well as the ramp inspector qualification process.

The CAA has published guidance on the procedures and quality standards for alcohol testing on the UK Ramp inspection programme page of the CAA website.

Specific recurrent training on alcohol testing will be addressed in an update to ARO.RAMP.115 in due course.

National limits of alcohol are defined in ARO.RAMP.106(e) and are commensurate with those in other transport regulations.

Whilst the regulation currently only requires operators to have a support programme available for flight crew, they may choose to make support programmes available to all their employees, including all safety sensitive personnel.

We asked for comments on our proposals for revisions to the existing CAA Charges Schemes, due to take effect from 1 April 2023.

We received 835 submissions from 672 stakeholders.

Full details have been published in our consultation response document. 

We ran a consultation, CAP2335, from 18 October to 16 December 2022 asking the UK General Aviation (GA) community for their views on our proposed strategic direction for pilot licensing and training simplification.

The consultation covered the following themes:

• Assessing the community’s overall view towards this project and the need for licensing and training simplification;
• Creating a single set of Private Pilot Licences (PPL) for aeroplanes and helicopters that comply with International Civil Aviation Organisation (ICAO) standards;
• Creating a single set of aeroplane and helicopter pilot licences that do not comply with international standards. Such ‘sub-ICAO’ licences are designed for flight in UK airspace only and subject to certain limitations;
• Proposing to better integrate the syllabuses of the sub-ICAO licences with the ICAO PPL to allow holders to progress more easily from one to another;
• Gauging views on the framework for balloon pilot licensing regarding commercial non-passenger and passenger-carrying balloon operations.
• Confirming the continued implementation of the Sailplane Pilot Licence framework; and
• Developing an approach to honour the validity of licences/ratings after we create new regulations: we proposed four options on how existing licences should be treated after a new licensing system comes into force.

We received 1,246 responses to this consultation. All respondents answered the survey questions and most left detailed comments.

• Overall direction: the vast majority who expressed a view agreed with the need for licensing system simplification, including over half agreeing strongly, indicating a clear mandate from the community to proceed with this project. A strong majority also agreed that this review should go beyond just a simple consolidation of the UK and retained regulations.
• Technical proposals on ICAO and sub-ICAO licences and consolidating the syllabuses: the vast majority supported each of our proposals indicating a clear mandate for progressing the technical details.
• Balloon licensing: the majority of respondents who expressed a view favoured retaining a single balloon pilot licence with appropriate ratings for commercial non-passenger and passenger ballooning respectively, thereby supporting continued implementation of the Balloon Flight Crew Licensing (UK Part-BFCL) regulation.
• Sailplane licensing: an overwhelming support proceeding with the implementation of the Sailplane Flight Crew Licensing (UK Part-SFCL) regulation.
• Honouring existing licences after we create new regulations: two options were considered by respondents as most attractive: ‘deemed valid for life’ and ‘deemed valid until a sunset’.

We will be proceeding with the next phase of this project to develop technical details on licences, ratings, certificates and training syllabuses across the various aircraft categories within the scope of the project. As with Phase 1, we will do this collaboratively with the GA community.

• Technical proposals on ICAO and sub-ICAO private pilot licences and consolidating the syllabuses: we will be undertaking a risk-based process to develop of the details both internally and within an expanded GA community working group.
• Balloon and sailplane licensing implementation: we will be progressing our previous decision to implement the UK Part-BFCL and UK Part-SFCL regulations, and to convert licences to the BPL and SPL respectively to operate Part-21 aircraft. To assist with this, the Department for Transport will be amending in legislation the implementation deadline by an extra year to September 2025.  
• Balloon and sailplane pilot licensing reform: we will be working with balloon and sailplane experts to explore how UK Part-BFCL and UK Part-SFCL respectively could be improved as part of this wider licensing and training simplification project.
• Honouring existing licences after we create new regulations: we will further examine the merits of the two remaining options with respect to safety considerations, transition costs, practicality, and wider (eg ICAO) developments in pilot licensing.

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

• GA Pilot Licensing & Training Simplification Phase 1 Strategic Direction - Consultation Response Document

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.

We also proposed AMC to give effect to the intention of working arrangements and to enable the CAA to permit the installation on UK registered aircraft of components maintained by approved organisations based in the state of signatory national aviation authorities.

We received 18 responses.

We received clear support for the CAA to take steps to make clear which components released on an EASA form 1 are acceptable to be fitted on a UK registered aircraft and when components cannot be.  You said that this clarity could best be achieved by making acceptability determined by the date of the EASA Form 1.    

We also received comments relating to the potential absence of parts in the UK that will be acceptable to be fitted on UK registered aircraft after 31 December 2022 for ELA1 aircraft. You said this was a risk due to European organisations not seeking CAA approval.

We received no comments on the wording to give effect to the intention of signed working arrangements with other national aviation authorities.

We have decided to adopt new AMC to UK (EU) Regulation 1321/2014 (the UK Continuing Airworthiness Regulation) that is simple to understand and easy to comply with that enables:

• Components released on an EASA From 1 prior to 1 January 2023 to be fitted to a UK registered aircraft
• Components released by an organisation based in a state with which the CAA has a working arrangement (which includes maintained parts) to be fitted to a UK registered aircraft; and
• 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 OEM to be fitted to a UK registered aircraft.

We have also decided to publish GM to UK (EU) Regulation 1321/2014 (the UK Continuing Airworthiness Regulation) to make clear that if a part released on an EASA Form 1 does not benefit from the newly adopted Part ML AMC referred to above, and so cannot be fitted to a Part ML UK registered aircraft, the relevant process that must be followed is AMC1 to Part CAO.A.070(a)(2.8) or AMC 2 to Part 145.A.50(d) paragraph (2.8) respectively.

For responses to the original questions asked in the Pilot Medical Declaration (PMD) consultation from 2015 (CAP1284) as well as whether the implemented PMD system has contributed to flight safety and whether it was proportionate to the risk involved in recreational flying.

We also shared the proposed 3 options from an internal audit review of the PMD process as a whole.

We received 1770 individual responses and 2 responses from organisations.
57% of respondents were PMD holders. We received a clear indication that the majority of respondents felt that the PMD was contributing to flight safety and was proportionate to the risk involved in recreational flying with 91% agreeing.

We received additional comments from 917 individuals with proposed changes to the PMD system including but not limited to, introducing spot checks of PMD submissions, introducing more regular declarations, improving the application form on the portal and also the guidance on our application form and website.

The overwhelming theme, equating to over a third of the individual comments, was regarding the use of a PMD for students to fly solo, in particular, SPL students. 

We have concluded the analysis of all responses received and these will be used to guide the CAA in the way forward for the PMD project. The internal working groups will recommence over the coming months and will propose any changes to the PMD process and internal record management. The CAA will release a formal consultation on any changes to the PMD process towards the end of 2023.

For comments on the proposal to establish Recognised Assessment Entities under UK Regulation (EU) 2019/947.  

We received 10 responses.

There is a clear and significant majority in favour of the proposed change. Some responses requested more information about the increased future scope of the RAE function.  

We will provide our formal opinion to the Department for Transport shortly, in order to commence this regulatory change.

The regulations in the proposal will require the drafting of new Acceptable Means of Compliance (AMC) and Guidance Material (GM). As part of that process the CAA will publish details of any proposed increase in scope of the RAE function.

Furthermore, the CAA has already begun to engage with industry stakeholders on a number of topics such as remote pilot competency. The CAA is committed to transparency and will expand this engagement in due course prior to any formal consultation.  

It is vital that CAP 1395 Safety Standards Acknowledgment and Consent (SSAC) remains up-to-date and relevant, and that the CAA’s guidance material in this area remains proportionate, clear and unambiguous.

We asked for feedback from the regulated community on proposed amendments to CAP 1395 ahead of implementation of an additional class of SSAC (Class 5: Experience flight in an ex-military jet aeroplane).

We compiled a draft of CAP 1395 Edition 4 and consulted on it over 4 working weeks from 11 July 2022 until 05 September 2022.

A total of 65 unique comments to the draft CAP from 22 respondents were received.

55 clearly conveyed some sort of change, 7 suggested no changes and 3 were unclear or just agreeing to this additional class. Of these, 44 comments were textual in nature, suggesting revised wording or highlighting minor drafting points. Many of these comments were duplicated between respondents; and the other 11 comments were more substantive, with 6 comments calling for some sort of change of the underlying policy.

Of the 44 textual comments 15 were accepted (34%). Most of these comprised of suggested rewording of content for clarification. A further 10 comments were suggested where changes had already been made and 3 comments were noted as unclear / unspecific.

Of the remaining 16 we elected not to implement, most called for revision to text that had been carefully drafted in cooperation and consultation with other groups. Others asked for further expansion on material that is covered adequately either in this document or elsewhere. Some suggested the introduction of content that was thought not necessary and outside the scope of this CAP.

Of the 11 substantive comments, 4 will be implemented with 7 elected not to implement due to the suggestion already covered elsewhere or those suggestions requiring a fundamental policy change, which was not part of the consultation.

Now we have produced our consultation response document we are now drafting a final version of CAP 1395 incorporating the various textual and substantive comments received as part of this consultation exercise. We plan to complete and publish the revised and updated CAP 1395 in Spring 2023.

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

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

The following questions and themes were noted during the consultation.

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

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

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

We asked for feedback from the General Aviation (GA) community on our proposed changes to CAP 482, which was updated to accommodate the revised UK microlight aeroplane definition.

We compiled a draft of CAP 482 Issue 8 and consulted on it over six working weeks from 8 July 2022 to 19 August 2022. The consultation did not ask any specific questions and instead allowed for free text responses.

We received a total of 124 separate responses to the consultation on the proposed changes to CAP 482. Whilst most of the comments received came from individuals there was also valuable input from various organisations and associations.

A representative subset of the substantive comments received from the consultation has been included in a Comment Response Document.

The CAA formed a working group with the British Microlight Aircraft Association (BMAA) and the Light Aircraft Association (LAA) to review each of the consultation comments received. This resulted in some of the original changes proposed being amended. The rationale behind these additional changes is explained in the Comment Response Document.

We published a final version of CAP 482 Issue 8 and the associated Comment Response Document on 15 May 2023.

Whether to extend the Legacy and Transitional UAS provisions in the Open category.

We received 4,506 responses including 2,411 additional comments.

There is a clear and significant majority who favour an extension to both provisions beyond twenty-four months.

We have published a response document and podcast that explains the conclusions we’ve now come to and our recommendation to Government for taking the issue forward.

The purpose of the consultation was to seek views on a draft refreshed Airspace Modernisation Strategy (AMS), extending its coverage out to 2040.

We analysed in detail all 114 responses. 40% said major modifications were needed to our overall approach. Of that 40%:

• Residents, local organisations, a national environmental campaign group and local government bodies were mostly expressing concerns about Government environmental policy, which is outside the CAA’s remit and therefore the scope of this consultation.
• The General Aviation community was principally concerned with airspace access, the CAA not properly taking into account the needs of non-commercial aviation, or the outcome of past CAA airspace change decisions (which were also out of scope of the consultation). We believe that most of these concerns arose because of misconceptions of proposed AMS concepts.
• Commercial industry was mainly focused on how to deliver the AMS and its elements, rather than disagreeing with the strategic approach. This was a theme in other responses too – how it will be achieved, by whom and with what funding and resources.

Refreshed Airspace Modernisation Strategy

On 23 January 2023 we published the refreshed AMS as:

CAP 1711 Airspace Modernisation Strategy Part 1: Strategic objectives and enablers

CAP 1711a Airspace Modernisation Strategy Part 2: Delivery elements (including linked database)

Consultation response document

In November 2022 we published a consultation response document summarising what you told us and how we were taking those views into account in the refresh of the AMS.

The consultation responses helped us shape the detail of the refreshed AMS, but we concluded that we should make no fundamental change to our overall approach. Much work remains to be done as the deployment plans forming AMS Part 3 (deployment) are developed. We needed to set the strategy first.

Five areas where we concluded that more work is needed

• Sustainability as an overarching principle
• Delivery model for airspace change
• Governance and leadership of the modernisation programme
• Funding and resourcing the broader modernisation envisioned by the AMS
• Improving the General Aviation community’s perception of modernisation concepts (see for example our infographic Modernised Lower Airspace in the UK).

Next steps

We will continue work on delivery, including the existing programme and AMS Part 3 deployment plans, and in particular how to fund, deliver and oversee the broader modernisation envisaged by the refreshed AMS. 

Keep up to date through our Airspace Modernisation Strategy webpages.

The CAA undertook a detailed review of airspace usage and classification within the Cotswold Region under its new airspace classification review procedure (CAP 1991). Our Draft Findings Report summarised the activity undertaken to scrutinise airspace usage within the Cotswold Region. It set out the engagement feedback we received from our stakeholders, the findings from  the conversations we held with airspace control authorities, and demonstrated how we used our own detailed analysis combined with the insight from our engagement to inform our draft findings into the region. The report included our initial plan of volumes where a case could be made for a proposed amendment to airspace, as well as our other findings and recommendations where alternative solutions may be more appropriate.

We asked whether we had missed, misunderstood, or misrepresented anything in our report into the Cotswold Region. We also asked whether Areas of Intense Air Activity (AIAAs) should remain.

22 responses were received which we have published where we had permission to do so.

Half of the responses to the “Have we missed anything” question agreed that the report had not missed, misunderstood or misrepresented anything. The remaining respondees provided additional feedback either on the findings or on the process used to gather them.

The majority of the feedback made suggestions as to how charting could be improved to aid airspace use by all users, for example it was proposed that permanent and ‘activated by NOTAM’ ATZs could be marked differently. Respondents also expressed interest in being able to get earlier and clearer notifications when military airspace volume is activated. Some also questioned the current structure of Class A airspace and questioned whether it was feasible to raise the base level of less utilised Cotswold CTAs. Finally, we received some positive comments on the depth of analysis and the use of our Airspace Analyser tool to corroborate our findings, although some also questioned the potential limitations of the tool and our methodology.

In response to our question on the usefulness of AIAAs, the majority of the respondents agreed that they provided no use for pilots and increased chart clutter. Six respondents answered “Don’t know” and a few suggested they should only remain in some of the current areas. Only three responses stated AIAAs are useful for flight planning if they are current and not excessive.

We reviewed each response received and considered whether and how the views impacted our findings. Any updates to our report informed by the feedback received are set out within the report.

The CAA is already working with NERL on its VFR Charting Review. We will hand over the insight we have received in relation to AIAAs to inform this work. We will also pass on relevant insight to the MoD to inform their review of airspace needs and will follow up in both instances to understand how our insight has informed these reviews.

Our Final Report contains our final findings regarding airspace use in the Cotswold Region, including our final plan of volumes to take forward to the amend phase of the CAP 1991 process.

The purpose of this consultation was to ask for your views on our draft Statement of Policy on Penalties, as published in CAP2280.

Part 1 of The Air Traffic Management and Unmanned Aircraft Act 2021 (the Act) introduced new roles and powers for the CAA relating to airspace change proposals. The Act requires us to prepare, consult on and publish a statement of policy with respect to imposing penalties. Our draft statement set out the CAA’s proposed approach to imposing penalties, what factors we would use to determine the amount, and how we would consider aggravating and mitigating factors.

The consultation consisted of four questions, all of which invited free text responses:

1. Do you have any comments on the CAA’s proposed approach to imposing a penalty under Schedule 2 of the Act?
2. Do you have any comments on the CAA’s proposed approach to determining the amount of penalty?
3. Do you have any comments on the CAA’s consideration of mitigating and aggravating factors?
4. Do you have any comments on the CAA’s proposed approach to determining the form of penalty?

We received 11 responses in total, which are published here, where we have permission to do so. We asked respondents to place themselves in one of nine categories. Of the 11 responses:

• four were from members of the General Aviation community
• three were from representatives of the commercial aviation industry (airports or air navigation service providers)
• three were either users of remotely piloted aerial systems or their representative groups
• one was from someone from an organisation that provides social media commentary about remotely piloted aerial systems.

From our analysis of the 11 responses, we identified these themes:

• General concerns around the idea of forcing a sponsor to undertake an airspace change proposal, including when against their (business) interest – three responses referred to this concern, including that the process must be proportionate and include the right of appeal
• “Draconian” process and penalty amount – one response expressed concern that the process could put a company out of business
• CAA and ACOG’s involvement in the process – several responses made comment about the level of involvement of the CAA in the whole process; one comment suggested ACOG (the Airspace Change Organising Group, a separate and impartial unit within NATS (En Route) plc set up to prepare the airspace change masterplan) needed a code of conduct if it is involved in imposing penalties
• References to ‘persons’ – one response was concerned with imposing penalties on individuals, rather than organisations
• Evidence used by the CAA in determining the penalty – one response sought clarity on when evidence could be submitted
• Form of penalty – one response sought clarification on when one or both options (fixed or daily) would be used

Two responses commented on penalties for the inappropriate use or misuse of remotely piloted aircraft systems, which are the subject of Part 3 of the Act. While we always review all comments in full, we have not responded to these comments because they are out of scope for the purpose of this consultation exercise which relates to Part 1 of the Act only.

We have published the final version of our Statement of Policy on Penalties in Chapter 4 of CAP2431 Air Traffic Management and Unmanned Aircraft Act 2021 Part 1: Enforcement Guidance and Statement of Policy on Penalties.

This table summarises the changes we made to the statement as a result of the responses we received. It also explains why we did not change the document in response to other comments.

This diagram sets out a summary of the process prior to imposing a penalty.