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CAA Audits of Permissions and Exemption Holders

FlushVision

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I received an email this morning from the CAA, an extract is below...

CAA audits of permission and exemption holders

As part of the UAS Units regulatory requirements and oversight program the UAS Sector Team will soon be commencing audits of current permission or exemption holders.

These audits are either as a result of intelligence/information received against the operator or randomly generated to align with work being carried out by the team in a particular area of the U.K at a specific time. Going forward you may receive an email stating that you have been selected for one of these audits. Our intention is to try and provide as much notice as possible for ease in negotiating a suitable time for the audit to take place.

The audit schedule is likely to comprise the following:

  • Review of the Operations Manual and the procedures outlined within
  • A walk-through pilot competency and training. (including flight logs)
  • A demonstration of records management (including insurance)
  • A look at the platforms used and maintenance involved
Has anyone else received a similar email and if so, what are your thoughts?
 

Mrgs1

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Sounds rather invasive. Is this the new approach, interrogate the registered users, if there's an illegal activity, because it's easy? Could someone report a person just for the h ell of it, just to be spiteful, without any proof, and registered pilots would be subjected to this? To me it seems over the top, will this cause a dramatic increase in costs for users? The way it's worded though, it's almost singling an individual out, or a select few?
 

FlushVision

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Sounds rather invasive. Is this the new approach, interrogate the registered users, if there's an illegal activity, because it's easy? Could someone report a person just for the h ell of it, just to be spiteful, without any proof, and registered pilots would be subjected to this? To me it seems over the top, will this cause a dramatic increase in costs for users? The way it's worded though, it's almost singling an individual out, or a select few?
It's always been the case that the CAA had the right to look at a permission holder's paperwork/flight logs but, as far as I know, up until now they haven't been exercising that right. It looks to me, then, that going forward the CAA are tightening up on permission holders. I do know that there are some permission holders that operate without insurance especially since the CAA stopped requiring evidence of insurance cover at the time of the permission application. Indeed, I recall an email from the CAA on the 5th April 2017 that reminded us of the need for insurance and poining out in the extract below highlighted in green that the CAA could ask to see the insurance at any time...extract below...


Dear Permission Holder

UAV Number: XXXX

I am writing to remind you that under EC Regulation No. 785/2004 you are an “aircraft operator”. As such, you have insurance-related obligations for aircraft used for commercial purposes. These obligations include:

Article 4.1 Having insurance for your aviation-specific liability in respect of third parties (and cargo, if applicable) that includes war and terrorism cover

Article 4.2 Ensuring that insurance cover exists for each and every flight

Article 5.1 On request, to demonstrate your compliance with these insurance requirements

Article 6.3 (if applicable) having insurance of at least 19 SDRs per kg of cargo carried

Article 7.1 Having insurance per accident, for each and every aircraft, of at least 750,000 SDRs in respect of liability for third parties

The above is not an exhaustive list and if you have any concerns your insurance policy might not comply with the EC Regulation then please check directly with your broker.



If you apply to vary or renew your Permission [issued under article 94/95 of the Air Navigation Order 2016] you will need to provide evidence that your insurance meets the minimum requirements of EC Regulation No. 785/2004 before the new Permission is granted. In addition its ongoing validity will be dependent on you having insurance that complies with the EC Regulation.


End of exract
 

Mrgs1

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Surely someone will have to pay for this increased observation if it becomes the norm? A licence fee increase, to justify your piece of mind that your compliant.
 

FlushVision

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Surely someone will have to pay for this increased observation if it becomes the norm? A licence fee increase, to justify your piece of mind that your compliant.
well, ultimately, any increased costs to the permission holder to insure he/she is compliant will need to be passed on to the customer. Having said that, the permission holder should already have factored his expenses to remain compliant in his quotes to his clients anyway since the permission holder should already have been keeping his house in order from the outset. It's only those operators that haven't been fully compliant...not keeping paperwork up to date or flying without commercial insurance that will see an increase in costs to become fully compliant.

Speaking for myself, I have commercial insurance and am already diligent with my records so there will be no extra cost to me to remain compliant. I've always been ready for the possibility of the CAA knocking at my door. The question is: Can all other permission holders say the same?
 

Mrgs1

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With a lot of small self employed businesses we carry the extra cost for as long as we can, it's a cut throat out there, and easy to be undercut. I suspect your right, some will not insure themselves, hoping a catastrophe never occurs.
 
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I got the same email yesterday. It looks to me like a blanket email to all PfCO holders warning of impending, but randomly selected, audits. Unless the government is making a load of money available so they can claim to be being tough on drone operators (post Gatwick), I wonder how many of the current list of 5,665 PfCO holders they will actually have the resources to check on. Also, as the current PfCO system is being replaced in July with new procedures for operators, the timing for any sort of mass audit seems a bit odd.
 
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FlushVision

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I got the same email yesterday. It looks to me like a blanket email to all PfCO holders warning of impending, but randomly selected, audits. Unless the government is making a load of money available so they can claim to be being tough on drone operators (post Gatwick), I wonder how many of the current list of 5,665 PfCO holders they will actually have the resources to check on. Also, as the current PfCO system is being replaced in July with new procedures for operators, the timing for any sort of mass audit seems a bit odd.
Well, regarding the impeding new procedures expected in July, I'm still waiting to see what exactly they will be. I have a rough idea of what it will be all about and some of the implications for permission holders and, from what I gather, it won't be good for the 'one man band' operator since it seems that it will open the door to hobby pilots legally taking some commercial work from permission holders. With that in mind, my permission is up for renewal in April so when it comes to renewal I think I'll have to take stock of my position and seriously consider not renewing. It's hard enough now competing with non permission holders doing illegal work for next to nothing without having to compete against them when they can legally do it.

I agree. It is odd timing. IMHO if they were gonna start auditing operators they should have started doing it years ago to weed out those operators cutting corners and having an unfair advantage over those of us who try to stay fully compliant.
 

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