The drone laws are changing. Should you still take a PfCO, or should you wait until November 2020?
* Important Announcement *
- Any COPTRZ PfCO graduates who trained with us since 1st September 2019 up until 1st July 2020 will be able to take the A2 CofC Training and Theory assessment Free of Charge
- Don’t delay, take your PfCO now as the legislation doesn’t come into effect until 1st November 2020, A PfCO is a requirement for commercial operations until this time.
- Any current PfCO holder will be able to transition and renew their permissions into the new GVC without having to take another course (unless the Addition of BVLOS/A2 requirements are needed)
What’s changing on the 1st November 2020?
As the drone industry continues to grow, so does the legislation so whether you’re flying commercially or not there are some things you should know. Last November we saw the registration system become a legal requirement for UK drone owners and by the 1st November 2020 we’ll also be seeing some further changes. These changes will be about how flights are categorised and how pilots are trained and qualified.
It all started back in July 2019 when the European Aviation Safety Agency (EASA) outlined how, as of 1st Nov 2020, drone operations would no longer be a case of commercial or non-commercial. Instead, all flights will be assessed based on the level of risk involved, with three main categories, Open, Specific and Certified. As well as the risk assessment for flights there will be a classification system based on weight and certain features. You can read our previous article that explains the original announcement in greater detail here:
The system, which will be implemented by the CAA, is based around three core pillars, being “operation centric, risk-based and performance-based” and all relating to the safety of flights and the subsequent risk to any uninvolved third parties. Essentially, it means that even non-commercial pilots looking to fly in dangerous conditions could still require some form of legal permission or qualification.
In some ways, not a great deal will change for commercial operators. You’ll still need to be qualified to carry out your day-to-day commercial flights. However, we will see some notable changes to how pilots are trained, with both NQEs and PFCOs being replaced with ‘new and improved’ versions. Apologies in advance for adding to your already bulging glossary of UAV initialisms…
The changes are all listed under CAP 722B by the CAA with the catchy title ‘Unmanned Aircraft System Operations in UK Airspace – The UK Recognised Assessment Entity (RAE)’. The RAE part is the new name given to organisations who train and issue CAA-recognised certificates to drone operators – such as the team here at COPTRZ.
Previously, this was known as a National Qualified Entity (NQE) and, for the most part, things will remain much the same. According to the document, “the RAE Scheme has been developed to assist the CAA in assuring the competence of remote pilots for many of the ‘large volume’ VLOS (Visual Line of Sight) operations that require an operational authorisation,”.
Companies with existing NQE status can either complete an ‘RAE Transition Request’ or make the necessary application should their NQE renewal come before that 01 July 2020. This should streamline the process as long as the company in question can demonstrate to the CAA that it can meet the new, though largely similar, criteria.
There will also be a two-year transition period that carries over to 1st November 2022. That means, NQEs can still operate after next year’s date, but they won’t be able to issue the new RAE certificates.
What are the New Qualifications?
The first qualification is the ‘Open’ category, which is mainly for the fun flyers who are currently covered by the Flyer ID scheme. However, within that are a couple of sub-categories which do account for a degree of risk assessment and therefore will need a formal qualification. That is where the A2 Certificate of Competency (A2 CofC) comes in.
According to the document, “the A2 CofC is a remote pilot competency certificate primarily intended to assure safe operations of unmanned aircraft close to uninvolved persons. The certificate assures an appropriate knowledge of the technical and operational mitigations for ground risk (the risk of a person being struck by the unmanned aircraft).” In short, it’s a purely theoretical exam that covers a lot of the basic material you might study (or have studied) for your PFCO and seems like an extension of the current online competency test.
The test will cover three main areas: meteorology (both gathering data and understanding how it affects aerial operations), flight operations (basic procedures and understanding payloads and batteries etc.) and operating principles (flight planning, identifying dangers and mitigating risk). It will be a multiple-choice exam to be taken at an authorised RAE test facility, with 30 questions to be answered over 75 minutes – and a 75% success rate to pass (so rounded up to 23 out of 30). If you fail, you’ll need to re-sit the test with a fresh set of questions.
The General VLOS Certificate
The General VLOS Certificate (GVC) seems most likely to be the direct replacement for the PFCO and includes operations in the ‘Specific’ category. According to the new document, “the GVC is a remote pilot competency certificate which provides a single qualification that is suitable for VLOS operations within the Specific category. The GVC is acceptable for all VLOS operations conducted under a published STS (standard scenario) or PDRA (pre-determined risk assessment) and, in most circumstances, it will be considered an acceptable level of remote pilot competency within an operational risk assessment for any other VLOS operation.”
As well as a more detailed theoretical test, it will also include a practical flight assessment. The written test can be multiple choice, ‘long answer’ or a mixture of the two – that’s to be decided by the RAE and approved by the CAA. There will be 40 questions with a 75% success rate required (30 out of 40), with the key topics listed as “air law/responsibilities, UAS airspace operating principles, and airmanship and aviation safety”.
The practical flight assessment “is designed to provide assurance that the remote pilot being examined can safely undertake a wide range of VLOS operations within the Specific category, including those conducted under a published STS or PDRA, whilst adhering to a set of procedures contained within an operations manual.” That manual can be one that’s prepared by the pilot, perhaps as part of their training, or one provided by an employer, for example.
The pilot will be asked to conduct a specific series of manoeuvres, either as individual moves or as a sequence designed to simulate an aerial operation. It will begin with pre-flight actions, including mission planning, the usual pre-flight checks and a verbal briefing on how emergencies or a collision would be dealt with.
The in-flight procedures include situational awareness, demonstrating accurate and controlled moves, plus the ability to operate under “abnormal” conditions. The abnormal condition is such as a loss of power or stray civilians crossing your flight path. This will be wrapped up with a post-flight assessment, including securing the craft, inspections, debriefing and identifying where an occurrence report might be necessary.
Pilots will fail the practical exam if they have a single safety-related error, three ‘major’ errors, or seven ‘minor’ errors. However, fly like a pro and the GVC will be valid for five years from the date of your exam. After that five year period, it is not yet clear if you’ll need to retake the entire exam or simply re-apply for accreditation.
Continued Professional Development
Both the A2 CofC and GVC are expected to be seen as “building blocks” for further training and testing. Both also expect that students will already have the Flyer ID. It’s also noted that even for the A2 CofC theoretical test, students should also have had a “period of practical flight training” – whether that’s by an NQE/RAE or simply self-taught. Lying about your flight hours could count against you should something go wrong further down the line.
It’s worth noting that while both have certain categories in mind, each certificate could be considered legally sufficient to operate within other categories depending on the level of risk assessment involved. However, that would be for the CAA to decide.
In terms of building upon these qualifications, one such example was given in the new document, GVC Module 1. It covers “operations that involve an unmanned aircraft being flown beyond the VLOS of the remote pilot but make use of visual observers for the purpose of avoiding collisions” – something also known as ‘extended VLOS’ or EVLOS, rather than solo operators flying beyond visual line of sight (BVLOS).
It’s taken in sync with the GVC course, so no further theoretical testing is required. Instead, it’s a practical assessment based on “BVLOS operations with visual mitigation”. It covers operational planning and pre-flight considerations for you, the drone and your team, as well as in-flight communications, situational awareness and some in-flight procedures. Plus there’ll be some of those simulated ‘abnormal’ conditions thrown in to show that you can respond to any given situation in a safe and assured manner.
As for what else may follow, then the sky really is the limit.
What Will Happen to Your PfCO?
It’s a question that isn’t yet fully answered, but ultimately it is being phased out. There’s no immediate panic, though. Although the RAE system and the introduction of these new qualifications will begin on 01 July 2020, the PFCO and many other aspects of the existing framework will remain in place for the duration of the transition period. This means that from next July, all new pilots will be trained towards an A2 CofC or GVC rather than a PFCO, while existing PFCO holders will have until 2022 to make the change.
However, whether all PFCO holders will have to retake the full written and practical exams has yet to be confirmed. It could be that there’s simply a similar ‘transition request’ as with NQEs becoming RAEs, assuming the CAA is happy that all of the requirements for the GVC are met by your PFCO training. It might be that some additional training to fill in a few blanks could be required.
One important thing to note is that this doesn’t mean there’s no point in training for a PFCO until next summer (or a GVC as it will be from July) – indeed it could turn out to be in your interests to do just that. The specific details have yet to be confirmed, but EASA could look to implement certain changes to what these qualifications allow, and it’s thought they may be stricter than what your PFCO permits you to do (such as extending the legal distance you can fly from people and buildings). So having a PFCO in place before November 2020 could see you retaining that little extra legal legroom for the following two-year transition period.
All in all, very little may actually change except for the names, with your NQE becoming an RAE and your PFCO being replaced with a GVC – though not without a fair amount of behind-the-scenes admin being required. Obviously, if there is more to it, we’ll be sure to keep you informed as more details are released in the build-up to November 2020.
In the meantime, you can read the full version of the latest CAP 722B developments via the CAA’s website. And if you are thinking about training for your PFCO or any other aspects of aerial operations, we’re always ready and willing to help set you on the right path to success. Just contact us on 0330 111 7177 or send us an email on firstname.lastname@example.org
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