What the New UK Drone Regulations Will Mean For Your Business – Part 2

Transitioning from Permission for Commercial Operations (PfCO) to General VIsual Line of Sight Certificate (GVC): When, how, and why.

In part 1 of this mini-series, What the UK’s New UAS Regulations will Mean for Your Business in 2021, we provided a basic overview of how Civil Aviation Publication (CAP) 722, effective 31 December 2020, will guide the adoption of EASA Implementing Regulations when it comes to permissions and certification requirements for drone operators in the UK. 

In a nutshell, for the next three years, current Permission for Commercial Operations (PfCO) holders will be allowed to renew their PfCO and, in turn, receive an ‘Operational Authorisation’ (OA) with the same terms and conditions that they previously held.

However, by the end of 2023, these organisations will need to have their pilots convert their qualifications into General Visual line of Sight Certificates (GVC), and then apply for a new Operational Authorisation (OA)  that corresponds to the GVC rather than recommendation certificates from an NQE.

We’ll refer to that as the ‘GVC OA’ so as not to confuse it with the OA into which up-to-date PfCOs will be converted in 2021. 

This begs the question: given the inevitable transition from the PFCO-compatible OA to the GVC OA, should organisations currently operating with a PfCO make the GVC switch now or later?

In this article, we’ll explore a few factors to consider if you are on the fence about renewing your PfCO or making the GVC OA transition in 2021. 

Before we dive into these factors, here’s a quick reminder … if your organisation’s operations are consistently low-risk (i.e., feature slow-flying and light-weight aircraft), having your pilots get an A2 Certificate of Competency (A2CofC) could be a simpler and more cost-effective approach than having them get the GVC.

However, the A2 CofC isn’t likely to allow for most moderate-risk operations, which are key to most enterprise-level UAS programs, so we’re focusing on the GVC and PfCO for the rest of this mini series. 

Without further ado, here is an overview of the factors that your organisation should take into consideration when deciding whether to make the GVC switch now or later.

What types of operation does your organisation plan to do?

The CAA’s new regulations are focused on risk and mitigation, rather than whether or not an operation is commercial.

Future approvals of new use cases (e.g., EVLOS) will be based on this risk-based framework. So, in theory, converting to a GVC OA could allow your organisation to take advantage of new use-case approvals in the future by letting you operate under the most up-to-date framework.

In contrast, if you simply renew your PfCO and get a corresponding OA, you will not be able to expand into new operations within this risk-based framework. 

However, the process for getting special permissions under the GVC OA requires you to submit a extended-risk assessment, and other details, as per the current Operational Safety Case. And, this could pose a short term challenge to your organisation’s operations if you have a lag in approval and you need to conduct non-standard operations, such as EVLOS/BVLOS, or operations around people, during that time.

If your organisation has an Operational Safety Case (OSC) that enables you to conduct those types of operations under your Permission for Commercial Operations, you will maintain those permissions in 2021 and beyond as long as you renew your PfCO before it expires.

So, in short, if you rely on an OSC to get things done, you’re probably better off renewing your PfCO, as the process of getting approval for a new OSC will require time and resources.

How much are you willing to risk?

If your organisiation’s budget has been hard-hit by the pandemic, getting your pilots GVCs could be an untimely strain on your budget, as it requires each of them to attend an Recognised Assessment Entity (RAE)-run course consisting of theory training, a theory exam, and a flight skills assessment.

On the other hand, do your current procedures comply with the new regulations? Are you confident that your team fully understands what is required to fly in an FRZ?

If your answer to these or similar questions is ‘I’m not sure,’ then sending your UAS team to a GVC course can a great way for them to gain insights from instructors with years of experience as drone pilots, spin up on practical UAS applications through case studies and discussions, and get better at applying theoretical aviation knowledge to your organisation’s day to day operations.

By upskilling your team, you could save your organisation thousands of pounds in the future by making your operations safer, more effective and in line with current regulations.

What kinds of platforms and sensors do you want to use?

Finally, transitioning to a GVC OA could widen your UAS and sensor options, as the GVC OA platform maximum takeoff weight (MTOW) limits are up to 25 kilograms.

Currently, the PfCO only allows for a maximum of 20 kilogram (under the standard permission). An extra 5 kilograms of MTOW leeway opens the door to a lot of heavyweight platform-sensor combinations that could improve your organisation’s UAS program potential.

However, since a basic tenet of these new regulations is that existing permission holders should not be disadvantaged, it is likely (but not 100% certain as of now) that those who convert to the PfCO OA will have the same MTOW restrictions as those who get the GVC OA.

Are you looking to grow your drone team in the future?

Going forward, pilots trained to the GVC process will be allowed to fly under a GVC OA rather than a PfCO renewed OA. 

This means that all new drone pilots will need to be qualified under the GVC, not the PfCO process. In other words, you might not be able to add newly qualified pilots to your company’s OA if you are operating under your old PfCO.

If you want to expand your pool of UAS operators in the next few years, it may be prudent to make the switch to GVC OA sooner rather than later.

Hopefully the CAA will release more information on this in the coming months.

Bringing it all together

To sum up:

  • If your organisation doesn’t have a PfCO yet, you’ll need to the GVC OA no matter what, unless your operation fits A2CofC’s low-risk criteria
  • If your organisation has a PfCO, you might want to switch to the GVC OA if you:
    • Don’t rely on an OSC and want to take advantage of the new risk-based permissions framework
    • Want to use heavier UAS and sensors
    • Want to upskill your UAS operators with latest regulations
    • Want to expand your UAS operator talent pool
  • If your organisation has a PfCO, you might want to wait to switch to the GVC OA if you:
    • Rely on an existing OSC within your current permission or the standard current permission is sufficient to get things done
    • Are financially recovering from COVID-19
  • No matter what you decide, remember you will need to convert all Remote Pilots to GVC by Jan 2024!

Feeling overwhelmed?

There’s a lot of confusion about the new permissions and certifications protocol, and given the many factors for your organisation to take into consideration, you may feel overwhelmed. 

If you’re interested in going the GVC route, know that Consortiq is here to help you make that transition, regardless of where you got trained initially. As a former National Qualified Entity (NQE) and current Recognised Assessment Entity (RAE), Consortiq and will be offering industry-leading General Visual line of Sight Certificate (GVC) training to support the issuing of this qualification.

Candidates who have previously completed their training with us can convert their NQE recommendation across to the GVC.

For the moment, this will be based on the following factors:

  • Frequency of flying
  • Completion of an Operations Manual
  • Date of initial training

For most pilots, we’ve previously recommended an updated theory exam will be enough for us to issue a GVC. However, where frequency of flying isn’t maintained and initial training is before January 2020, it’s likely that you will need a new flight skills assessment and theory exam.

And if you’re simply not sure where to start, we can help with that too.

Our drone consultants bring with them a wide range of experience in the drone field and have helped clients ranging from startups to Fortune 500 companies develop UAS solutions that fit their specific needs.

If you’re not quite ready for that level of engagement, we’re also happy to provide you with free resources and insights into the UAS industry and regulatory developments via our blog.

Miriam Hinthorn - Contributing Author

Miriam Hinthorn - Contributing Author

Miriam Hinthorn is an experienced management professional who is currently pursuing her master’s in Data, Economics, and Development Policy at MIT while serving as principal consultant at Consult92.

Miriam developed a love for UAS technology when she served as operations manager at Consortiq. Today, having completed over 30 successful projects in 10 countries, she loves solving a wide variety of logistical, technical, and cultural challenges for her clients so that they can focus on what care about most.

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