CAA Drone Registration
DSR asks 6 Questions of the CAA and Government about the incoming drone registration process and fee
Long before the December 2018 Gatwick drone incident, the Government in compliance with the European Union Aviation Safety Agency (EASA), agreed to implement the EASA harmonised rules and regulations for safe drone operations. In 2018, the UK Government mandated a drone registration and education scheme in the UK to strengthen, they believe, ‘the accountability of drone users and their awareness of how to fly their drones safely’. This now being a matter of law, the registration stage will open from 1st October with all drone owners/operators to have registered their drones and remote pilots to have been tested by 30th November 2019.
Recently, the CAA have distributed a consultation questionnaire to obtain feed-back into the costing model and subsequent fees for the unmanned aircraft (above 250g) registration programme. The CAA have stated that the ongoing cost of running and maintaining the database application, user support and training (plus other activities) has been put at £2.8m. The government, who have funded the initial setup and implementation, have confirmed that the ongoing running cost must be met by those that register and therefore use/own drones and model aircraft and not the tax payer. The CAA have calculated the expected registrations to be 170,000 over the first 18 months and therefore the cost/fee to registrants will be £16.50.
Drone Safe Register, as a professional organisation representing the largest commercial community of approved and certified drone pilots in the UK and Ireland, are today registering concerns over the process, procedure, and cost of the registration scheme as it has so far been communicated and we have 6 very specific question we are putting today to the CAA.
In principle, DSR has no issue with the registration of drones both in the commercial sector and the leisure sector, as it has been offering registration services for quite some time, and very successfully. The first registration of a drone operator and their drone equipment was completed as far back as April 2014.
However, DSR feels that there is questionable justification for the planned fees involved. We accept that it will be hard to determine numbers for costing purposes in an industry that has simply exploded in recent years and with no real idea when the peak point of drone purchases will be reached, especially as the technology changes so radically and existing owners continue to buy more drones. However, it shouldn’t be difficult to establish the current volume of drones purchased in the UK over recent years as well as reviewing membership numbers of established drone communities. It appears that the CAA haven’t asked such groups or retailers for numbers which would give a more realistic understanding of the potential signups and therefore cost repayment.
Using population statistics and previous registration algorithms from countries like the USA and Ireland presents data from two very opposite ends of the population spectrum and is not sufficiently objective. There will also be different cultural attitudes to compliance to consider, as there will be many who own a drone for occasional leisure use who will simply not bother to register. There are plenty of penalties for driving illegally, however many still do, so the same will apply to drone registration for many. The consequences of getting the numbers wrong will only mean that the income shortfall will be passed onto drone flyers as the consultation paper indicates very clearly, and so we think it is fair to say that the initial £16.50 will increase at the first review point significantly.
DSR has always sought to work with the drone industry, the CAA and Government, and of course welcome being invited to take part in the CAA select stakeholder’s group, however, we have several very real concerns that need to be voiced regarding the process of Drone Operator and Drone Pilot Registration.
Commercial PfCO Pilots and Operators
When addressing the commercial sector, it is a fact that commercial drone operators have been ‘registering’ for some time. They also pay a significant fee for doing so, which has been increased by over 50% since 2017. While the consultation paper is clear that commercial operators, like leisure users, will need to register what remains unclear is how two very different drone user groups can be treated and considered the same.
There is no justification and appears completely ludicrous for a commercial drone pilot who has already completed ground school, flight assessments and classroom testing, as well as undergoing operational scrutiny by the CAA when submitting their operational manuals, to then be required to take a basic online test targeted at leisure flyers. What is clear is that there will be a significant number of leisure users who would have purchased a drone or received one as a gift and moved swiftly from opening the box to flying in the garden without any understanding of the regulations and risks associated, where is the manufacturer’s responsibility to safe product use? Education and compliance training are long overdue in this very specific category, but how does that sit with a professional commercial operator or pilot with years of experience, training and certification? Shouldn’t there be a requirement upon the manufacturer at their expense to educate safe and complaint use of their product?
The CAA are clearly aware that the commercial sector is naturally risk averse, fully conversant of not just the Drone Code, but aviation airspace rules and regulations in detail. Why would the CAA require PfCO holders to then be included into a ‘dumbed down’ process, when they have already been through one at a much greater depth? Commercial drone operators have a vested interest in securing their livelihood, so to put that at risk by operating illegally, unsafely and in anyway non-compliantly is absurd. In addition to that outlined above, Commercial Drone Operators are subject to random auditing by the CAA, where flight records, maintenance records and knowledge of their business’ operations manual is fully tested. All this from a view point of no fatalities or known significant injury to anyone as a result of a commercial drone operation.
The following are open questions we put to the CAA today: –
Will PfCO holders be exempted, grandfathered, or respected in the registration process and how does this process complement the fact that they are already registered and trained?
Will the PfCO holder’s existing training and qualification certification be enough to satisfy compliance for Remote Pilots?
Is the PfCO process to be harmonised or absorbed into the EASA registration requirements?
With 85% of drone operators and pilots being one and the same, which is the correct registration process to take – a) Drone Operator or B) Remote Pilot? Why is A an annual renewal and B a three-year renewal?
Leisure and Amateur Flyers
The need for registration in the leisure and amateur flyer sector is fully respected and expected by DSR, and in many ways long overdue. With many existing drone bodies and organisations already offering membership and registration schemes, such as the Drone Safe Register Amateur Flyers, why does the CAA feel it is necessary to reinvent the wheel and create a new database and procedure, when many already exist?
Existing bodies such as BMFA and FPV UK as well as DSR Amateur Flyer membership, along with other similar organisations, could easily accommodate the CAA brief to trap data to comply with the registration requirement. Furthermore, these entities have a much better track record than government bodies in building, maintaining and supporting membership and registration applications. With the ‘added value’ of having membership with these organisations, the incentive for amateur flyers in the leisure sector to sign up in the first place is much more probable, after all, this regulation is aimed at them surely, and in particular, those that don’t fly responsibly and in ignorance of the law.
It is easy to then provide this membership data under GDPR to the CAA or a government department as required to meet the registration requirements. Government has a bad track record for delivering IT projects, so why not work with, and through the existing infrastructures?
Our other concern is that the CAA communication and the EASA harmonisation process suggests no distinction between commercial operators and leisure drone flyers, with the introduction of categorisations “Open”, “Specific” and “Certified”. This may suggest to leisure flyers that they are now registered or licensed and can make commercial gain from their part-time leisure photography and videos.
Further questions for the CAA: –
Will there be clear separation between commercial operators and leisure flyers both in the registration numbering system as well as the online testing to ensure that leisure flyers are not mistaken into thinking they can operate for commercial gain? We suggest a clear registration number for example, C###### (commercial) and L###### (leisure) which will tell for example, law enforcement who the operator is very quickly when reviewing drone activity and therefore allowing commercial operators to go about their lawful business quickly after being interviewed on location.
Will the CAA look at working with existing drone and model flying organisations for data registration and compliance recording, to save cost and ensure an easier implementation and a more sustainable drone use future?
Following the Gatwick incident where credible evidence of drone misuse has yet to be presented, we, along with thousands of other drone users, lobbied MPs and government departments to not knee-jerk into more unnecessary regulation and to understand that the current regulations were adequate, the problem was simply misuse was not enforced. But government went and did it anyway, with increasing exclusion zones distances around airports and aerodromes, causing confusion among airport operators and despite accepting that this would never stop a future incident like that at Gatwick from occurring again. We don’t hold out much hope that anyone is listening but will continue to work with the CAA to support, represent and endorse safe and compliant drone usage in the UK for both commercial operators and leisure users alike.
Drone and Model Aircraft flyers can play their part by assisting the CAA in refining this process of compliance by completing the CAA online consultation. The more that do the clearer the indication as to the likely number of potential registrants there will be in the autumn, which is probably the most singularly important thing we can all do to help determine the appropriate fee for a registration requirement that is coming in any event.
Please ensure you answer the CAA Consultation Questionnaire – “Charge proposal for the UK Drone Registration Scheme”