FlushVision
Premium Pilot
Yes, although the CAA do seem to be getting tougher on PfCO applications and renewals particularly with getting shirty over the Ops Manuals, I do get the impression that they are also becoming slightly more relaxed when it comes to special wavers. For example, I gather that we are now allowed to do night flying so long as the Ops Manual submitted reflects safe operations for night flying.The CAA seems to closely follow our original 333 process, where everything had to be documented, reviewed, and approved by our FAA. In a way some of our 333 process wax worse as it allowed public comment in some areas. Full scale commercial pilots, commercial unions, and a few individuals were extremely negative with every application submitted. Muddied the water more than anything else. However, our 333 process permitted those awarded one a lot of latitude to apply for waivers to operate under some pretty difficult conditions and permitted them to operate at a higher general altitude than later 107 operators.
The implementation of Part 107 greatly simplified the process and does not require a documentation package, but does suggest developing one. In time we should expect documentation to become mandatory instead of optional. When that happens it will be interesting to see how demanding they become.
I received an email from the CAA last week warning of the need to update ops manuals to reflect changes in the law and I expect that other PfCO holders received the same email...so they are now telling us about changes in advance...something that they didn't seem to do until now. But I agree with @Ren57 what we are now supposed to include in our ops manuals is getting a bit stupid. My ops manual is currently 52 pages long and that's without having updated it to reflect recent changes in the law. If I do update my ops manual (now very doubtful) to renew my PfCO, I can see it easily going up towards a page count of 60.