Will CAP1789 kill off the requirement for a PfCO?

The CAA sent out Information on the proposed New European UAS Regulations last week via CAA Skywise. Identified as CAA1789, this proposes very significant changes on who, where and with what you can fly a drone. If thinking of paying for a PfCO, you may want to hold fire. This is because CAP1789 implies will mean that your do not need a PfCO to sell images as ‘commercial purpose’ for a flight will longer be a factor.

However, it’s not as simple as that and Ikopta gives a very good explanation of the implications on his YouTube channel.

Here is the link to CAP1789 http://publicapps.caa.co.uk/docs/33/CAP1789%20EU%20UAS%20Regulations-Guidance.pdf


The regulations are intended to follow three basic concepts as follows:
 Operation centric – the focus is on the type of operation being conducted, rather than who or what is conducting it, or why it is being done. Because there is ‘no one on board’ the aircraft, the consequences of an incident or accident are purely dependent on where that incident/accident takes place

 Risk based – the focus is on the risk that the operation presents, and so more effort or proof is required where the risk is greater. One outcome of this is that there will no longer be a requirement to hold an operational authorisation purely on the basis that an unmanned aircraft is being flown for commercial purposes – it is the risk of the operation that is the deciding factor

 Performance based – the primary requirements are aimed at identifying the required capabilities, or performance levels, rather than creating a set of prescriptive rules

UAS operating categories
Tied in with the ‘operation centric’ concept above, operations of unmanned aircraft will fall into one of three categories as follows:

Open category – operations that present a low (or no) risk to third parties. Operations are conducted in accordance with basic and pre-defined characteristics and are not subject to any further authorisation requirements.

Specific category – operations that present a greater risk than that of the Open category, or where one or more elements of the operation fall outside the boundaries of the Open category. Operations will require an operational authorisation from the CAA, based on a safety risk assessment.

Certified category – operations that present an equivalent risk to that of manned aviation and so will be subjected to the same regulatory regime (i.e. certification of the aircraft, certification of the operator, licensing of the pilot)

The key part for ‘hobby’ pilots is the Open Category

Open category operations are bounded by three main factors:

 the maximum take-off mass of the unmanned aircraft must be less than 25kg
 the unmanned aircraft must be operated within visual line of sight (VLOS)
 the unmanned aircraft must not be flown further than 120 metres (400 feet) from the closest point of the surface of the earth
All three of these factors must apply for an Open category operation. If not, then the operation must be conducted under the requirements of the Specific category instead.

The Open category is then further divided down into three operational ‘subcategories’, in order to allow different types of operation without the need for an authorisation, as follows:

 A1 (fly ‘over’ people) – Operations in subcategory A1 can only be conducted with unmanned aircraft that present a very low risk of harm or injury to other people due to their low weight (less than 250g), their type of construction, or because they are a ‘toy1’ (i.e. they are ‘inherently harmless’). However, flight over open-air assemblies of people is not permitted.

 A2 (Fly ‘close to’ people) – Operations in subcategory A2 can only be conducted with an unmanned aircraft that is compliant with a specific product standard (and a maximum mass of less than 4kg), but this unmanned aircraft can be flown to a minimum safe horizontal distance of 30 metres from uninvolved people, or down to 5 metres horizontally when its ‘low speed mode’ is selected. In addition, the remote pilot must have successfully completed an additional competency examination in order to operate in this subcategory.

 A3 (Fly ‘far from’ people) – This category covers the more general types of unmanned aircraft operations. The intent is that the unmanned aircraft will only be flown in areas that are clear of uninvolved persons and will not be flown in areas that are used for residential, commercial, industrial or recreational purposes (roughly equivalent to what is currently referred to as a ‘congested area’).

The aircraft classification is also going to become very important

A key element of the Open category is that any unmanned aircraft that are sold for use within this category will also be subject to a set of product standards, similar to the ‘CE’ marking scheme. In order to achieve this standardisation, unmanned aircraft that are intended to be sold within the ‘EU market’ have been further subdivided into 5 ‘classes’. These classes provide a link to the operational subcategories as follows:

 Class C0 - (can be flown in all subcategories) Very small unmanned aircraft, including toys, that:
 are less than 250g maximum take-off mass
 have a maximum speed of 19m/s (approx. 42.5 mph)
 are unable to be flown more than 120m (400ft) from the controlling device

 Class C1 – (can be flown in all subcategories) Unmanned aircraft that:
 are either:
 less than 900g maximum take-off mass, or;
 are made and perform in a way that if they collide with a human head, the energy
transmitted will be less than 80 Joules
 have a maximum speed of 19m/s (approx. 42.5 mph)
 designed and constructed so as to minimise injury to people
The standards also cover other aspects such as noise limits, height limits and requirements for
remote identification and geoawareness systems.

 Class C2 – (can be flown in subcategory A2 [close to people] or A3 (far from people) Unmanned aircraft that:
 are less than 4kg maximum take-off mass
 designed and constructed so as to minimise injury to people
 are equipped with a low-speed mode’ which limits the maximum speed to 3m/s
(approx. 6.7 mph) when selected by the remote pilot
The standards also cover other aspects such as noise limits (but different from C1), height limits and requirements for remote identification and geoawareness systems, plus additional requirements if it is to be used during tethered flight.

 Class C3 – (flown in subcategory A3 [far from people] only) Unmanned aircraft that possess automatic control modes (such as found in typical multicopter ‘drones’) which:
 are less than 25kg maximum take-off mass
The standards also cover other aspects covering height limits and requirements for remote identification and geoawareness systems. There are also additional requirements if it is to be used during tethered flight, but there is no specified noise limit (because the aircraft is intended to be flown ‘far from people’).

 Class C4 – (flown in subcategory A3 [far from people] only) Unmanned aircraft that do not possess any automation, other than for basic flight stabilisation (and so are more representative of a ‘traditional’ model aircraft) which:
 Are less than 25kg maximum take-off mass
A diagrammatic representation of how the subcategories and UAS classes are broken down is below


I think the CAA will have to clarify the need for PfCO as and when this comes into effect. As at present this isn’t set in stone.
Plus they will lose a source of income.

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I think you are right as this is where the Specific category comes into play: (from CAP1789]

The simplest description of a Specific category operation is that it is a UAS operation that ‘cannot be done within the Open category, but is not complicated enough for the certified category’.
The key point to note is that the category hinges on an operational authorisation being held by the UAS operator, which has been issued by the CAA, before the operation can be commenced.
For UK UAS operators, the process should be very similar to the current permissions and exemptions process in that the UAS operator is required to tell the CAA:
 what, where and how the unmanned aircraft will be operated;
 demonstrate that the operation is ‘safe enough’ through the provision of a safety risk
assessment/safety case.
Note: In some cases, the requirements for a ‘full’ safety risk assessment may be able to be lifted if the CAA considers that this is not required but is instead covered by a lesser degree of documentation, as a ‘pre-defined risk assessment’. It is anticipated that the application process for the replacement of the current ‘standard permission’, issued by the CAA for operations within congested areas and for commercial operations, would follow these lines.

Interesting, if we or the hobby lasts that long.

@MementoMori moved your post to the existing thread on this topic from a few days ago :+1:t2:


Cheers Rich, not been as active here recently and missed this.

Just seen this advertised at me. May be of interest! (DJI webinar on the subject)


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This is the link to the recording which you can skip through https://register.gotowebinar.com/recording/6201209696725215756

For most people the open category is all they need to worry about and what they can and can’t do with their drones. This is covered in the slides below:

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And here is the conclusion slide


I’m guessing this will be offset, or even increased, by the drone registration programme :+1:t2:

Until they realise no one is registering :wink:

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Actually on reading what I have of CAP1789 all it says is the regulations for hobbits and commercial pilots will be the same. It doesn’t at any point say that you won’t need a PfCO or equivalent for commercial operations. So the CAA may keep the PfCO in place as they are the ones that regulate UK airspace.

Every country has to have it’s one registration process in place, but on the webinars it was suggested that this should mean that you would only have to register in your own country and then be ok to fly in the rest of the EU as the registration and online test would be a minimum standard. Suggested also would be the same for the new equivalent of the PfCO.

According to the table above you would need the PfCO equivalent to fly a drone of more than 900g close to people, such as over populated areas. Similar to being able to fly a Mavic 2 ( though expect the M3 to be under 900g!) or an Inspire over built up areas as now.

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