OA renewal- CAA in mega-picky mode?

Legal & Privacy
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Hi there.

Wondering if anyone here has renewed an OA recently?

Last year mine sailed through easily, no comment. This year, same OSC, basically the same operation just some minor changes (added some extra drones) plus a legislation update, I had responses from 3 different people and they want different things- and I am at the point where I don’t know which submitted document they are referring to.

What is clear is that if you are a small operator working to UKPDRA01 and you want to renew your OA, your chances of satisfying the pickiness test is minimal unless you pay an RAE first to review it. So you will need to pay £150 or so to an RAE as well as forking out the £250-odd quid to CAA. There’s no way that the guidance in CAP722 is enough any more.

I would prefer it if the CAA just had the initial review done by RAEs every year, and reduced the application fee. At least the OSC would then be reviewed by a person who reads/understands it and with whom you can have a conversation.

The whole point of UKPDRA01 was to have a simple means of getting OA for a small operator. But the way CAA have moved in recent times, that’s no longer so. There’s obviously a magic tick-list and use of a search function and if you have a phrase/term on their tick-list you fail. I don’t believe they are reading beyond this. Certainly no sense of proportionality or risk- it’s all purely tick-box based and having the right phrases, you will fail if you use an incorrect phrase even if the substantive meaning is the same.

The most galling thing is that CAA is being mega-picky- but has yet to update CAP722 to remove the glaring error in UKPDRA01… (see: assemblies of people, distances from…). But if you put in your ops manual what is in CAP722 they will treat that as an error… :exploding_head: :exploding_head: :exploding_head:

I wonder what on earth is going on.

GC

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Put mine through a couple of weeks back - only thing they complained about is I used my Sunday name in my Ops Manual and shortened it when filling out the online form. Schoolboy error, easy fixed. Had the OA through well within a fortnight.

But having said that, I admit that it did go through an RAE for checking first - not £150 though, came in at less than the CAA fee for rejection/reassessment so made sense to me.

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I’m just getting ours ready … UAVHub have a decent guide on changes free online.

That said, what particular things were they picky about?, so I can check ours :wink: !!

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Lots of things, basically if you have a phrase on their banned list you will fail. Hopefully your RAE has managed to get a list of banned phrases together so that you can use that as without it, chances are reduced. Legislation is another big one, assuming you can figure out where they are up to.

Also there is the issue of the error in CAP722/UKPDRA01, if you quote the content of the PDRA as per CAP722 you (might) fail- which is bizarre as this is apparently an authoritative document, and I was always taught that if there’s 2 documents at odds, always go for the option that is safer.

Version control: don’t expect the assessor to be able to tell the difference between a “document reference number” and a revision/issue status.

Yes, I made some school girl errors in my original (such is life), but after correcting that it all got very strange.

I don’t think the documents are being read by competent people, instead there seems to be a bunch of people who have a ticklist and use the “search” function to find banned phrases. If you get a helpful one who has a bit of knowledge- great. If not- bad luck.

Won’t necessarily be the same person who looks at your amended version to the person who looked first time, it might be a different person who wants other stuff. You might get different replies from different people, or you might not be able to tell which version they are referring to.

I didn’t know about the UAVhub guide, I will see if I can find that, but either way, even if you had no bother last year, I strongly recommend you get it checked by a RAE first.

I expect mine will get chucked out again, they just seem now to be in a mode of “what can I pick on to reject this,” admittedly I did have to point out it was difficult to work out what the date should be for CAP1789A when the CAA summary says 28 June 2022, the document says inside it is dated 22 June 2022 and the document header says July 2022. Take your pick of the reference date you wish to use and hope the assessor uses the same one. (My pick is 28 June 2022).

I have come to the conclusion that the process is to a large degree about luck, who picks up the assessment initially.

Makes a mockery of the whole thing though, on one hand you can pass a flying test on a Mini then with no further ado go and get a gurt big M600 to fly, on the other hand if you get a phrase wrong on an OA renewal you won’t get an OA renewal; and they don’t publish the magic phrase list you need (and after 2 goes it’s reapply, another fee- k’ching!). CAA seem to have thrown out the window any sense of proportionality and risk.

If they want a system where the renewal must go via an RAE first, fair enough; then reduce/remove the fee they charge, cull the CAA assessors and nod through on RAE recommendation.

The irony is that the main risk from drones will come from those operating illegally, the CAA certainly seems to be doing all it can to stifle small operators who try to work legally rather than going after the naughty people. I wasn’t aware that a high-level qualification in technical authoring was required to be a drone operator, but hey ho, life is full of surprises, not all of them nice ones.

Working on another version which will go to an RAE for detailed nit-pick ready for the inevitable rejection and re-submission.

:rage: :rage: :rage: :rage: :rage: :rage: :rage: :rage: :rage: :rage:

GC

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Hi @ximi, I cannot see the UAVhub guide, I suspect you need to have trained with them and have an account. I see they do a checking service- for a fee.
Just reinforces my view that you need a use commercial service which is close to CAA insiders to be able to not just obtain but also to renew an OA, poor chances otherwise if you’re a small operator.
Another £119-£125 to add annually to CAA’s fees. :weary: :face_with_symbols_over_mouth:

GC

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Oh … I found it here. Updating your Operational Authorisation Operations Manual for 2022

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And thanks for the feedback … yes, they do seem to want stock phrases, and woe betide you if you get the document issue mistyped!

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Aye well I think a question needs to be asked about how this persnickety and unhelpful spproach squares with CAAs duties under the Equalities Act as a public body.

A dyslexic person could be a perfectly capable operator, highly competent but a one person operation, and (from my experience of a much respected colleague), would likely struggle to pass the persnickety test without paying a specialist, putting them at disadvantage.

These are not safety issues, these are persnick points.

The thing with UAS operations (as opposed to manned aviation) is that a prospective OA holder could well be a small one person band (as I am, and this is far from being my day job, indeed my day job business currently subsidises development of the drone business). A level of pragmatism and propotionality is called for methinks. Particularly given the uncorrected errors in 2 key CAA documents (CAP722 and CAP1789A)- CAA are applying a standard to low-turnover one-person operators that they do not meet themselves!

The UAVhub guide has some points in but by no means all. I now have a much longer list of persnickey points which may/may not (depending on how lucky you get) lead to rejection.

I will make some more detailed notes when I get chance (and am using main PC not my tablet!)

GC

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Well, I’m due to submit next week, anything that they point out on mine I’ll feed back buddy.

Onwards and upwards !

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This link may also be helpful. It is not necessary to pay anyone to check your OA. With time sent on the links provided here, you can do it yourself for nothing. Hope this helps.

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OA, OSC, UKPDRA01, RAE, CAA, CAP722.
We are getting more like a government department, but I wonder what new flyers think about such posts.

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:dizzy_face: :exploding_head:

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Perhaps the same as I feel when I head over to the FPV and self-build sub-forum? There’s some amazing knowledge on there which makes my head explode and fills me with admiration in equal measure.

There used to be a limited PfCO sub-forum where we could put these questions, but its gone now.

As a one-person band operator with a OA, I have found it really helpful to find I am not alone in my travails and appreciated the response from others on here, in the same way I appreciate the replies to a query I posted in the FPV-Self-build sub-forum as I am taking my first tentative baby steps away from the DJI ecosystem… which I am finding proper scary (but fun).

This sub-forum is about legal and privacy and unfortunately the legal bit can be complex, but thanks to very knowledgable people on here there’s a fabulous “where can I fly” decision thngie to help those new flyers.

GC

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Well, just got mine through, no issues. I’d updated in line with the online sources posted above.