IN-2014/184: Small Unmanned Aircraft: Congested Areas Operating Safety Case (CAOSC)


The purpose of this Information Notice is to inform operators of civil Unmanned Aircraft Systems (UAS), wishing to operate in congested areas, of the requirement to submit a safety case for assessment by the CAA. The rapid increase in operators wishing to conduct operations in support of commercial work, particularly for Small Unmanned Aircraft (SUA) and Small Unmanned Surveillance Aircraft (SUSA), has led to the requirement for a higher threshold of safety to safeguard the public; operators who meet this higher threshold will benefit from less restrictive limitations and an annual based permission (as opposed to a case
by case non-standard permission).

1.2 Assessment of submitted CAOSCs will consider all elements of the operations (including airworthiness). Whilst this Information Notice is mainly aimed at SUA and SUSA, Unmanned Aircraft Systems (UAS) in other categories, under UK CAA competence, may be allowed to use the safety case approach when applying for permissions or exemptions; however, prior agreement from the CAA must be obtained in such cases. This Information Notice should be read in conjunction with IN 2014/081 Small Unmanned Aircraft Operations within London and Other Towns and Cities.

1.3 This Information Notice supersedes IN-2014/179

2 Definitions

2.1 A ‘Small Unmanned Aircraft’ is defined in Article 255 of the Air Navigation Order (ANO) 2009:  ‘’Small Unmanned Aircraft’ [SUA] means any unmanned aircraft, other than a balloon or a kite, having a mass of not more than 20 kg without its fuel but including any articles or equipment installed in or attached to the aircraft at the commencement of its flight.’

2.2 A ‘Small Unmanned Surveillance Aircraft’ is defined in Article 167(5) of the ANO 2009: ‘In this article ‘a small unmanned surveillance aircraft’ means a small unmanned aircraft which is equipped to undertake any form of surveillance or data acquisition.’

2.3 A ‘Congested Area’ is defined in Article 255 of the ANO 2009: ‘’Congested area’ in relation to a city, town or settlement, means any area which is substantially used for residential, industrial, commercial or recreational purposes.’

3 Requirement

3.1 All SUAS and SUSA operators applying for permission to operate in congested areas are required to complete a CAOSC in the format detailed at the Congested Areas Operations Safety Case Template. SUA of 7 kg or less are not required to use the CAOSC for a standard permission

3.2 It is recognised that elements of the CAOSC, specifically Chapters 3 and 5, replicate information already held in Operations Manuals; with this in mind, operators will be permitted to refer out from the CAOSC to the Operations Manual as opposed to duplicating the detail. Operators should however ensure that any changes to the Operations Manual do not significantly affect the CAOSC. Where changes to equipment, company policy or operating environment (within the period of a current permission) significantly affect the CAOSC, a new application for reassessment must be made.

Guidance contained within the CAOSC template should be followed when compiling the document.

3.3 For SUAS and SUSA applications, it is not expected that complex hazard identification and risk assessment techniques will be used (e.g. Goal Structured Notation). Hazard identification and risk assessment should be undertaken using basic techniques and recorded in the format provided.

3.4 The self assessment must be unique to the applicant and must cover all aspects of the intended operation. This section is perhaps the most important in the CAOSC and applicants will be assessed against their ability to demonstrate that robust safety arguments have been made.

3.5 Documents used as supporting evidence should be attached to the application and clearly identified. Applications submitted via electronic media should contain scanned original signatures and not statements suggesting that originals have been signed.

4 Further Information

4.1 A period of three months from date of issue of this Information Notice will be allowed for those operators wishing to continue to apply for a case by case non-standard permission. Thereafter all applications must be accompanied by a completed CAOSC. All current permissions will remain extant.

4.2 All CAOSC assessments will be conducted initially by the CAA under the Special Survey process. Once a baseline methodology has been established it is envisaged that assessments may be undertaken by an appropriately accredited body.

4.3 All applications should be made using the Special Survey Application Form. The cost of investigations associated with such a Special Survey is £134.00 per hour. An estimate of the costs will be given at the time of initial application.

5 Queries

5.1 Any queries or requests for further guidance as a result of this communication should be addressed to [email protected] mailbox.

6 Cancellation

6.1 This Information Notice will remain in force until further notice