For the current crop of 3100+ UK CAA Permission for Commercial Operation (PfCO) holders the Small Unmanned Aircraft (SUA) industry has quickly become competitive in nature. To distinguish themselves in this market – in essence to ‘be a blue cow in a field of black and white cows(!)’- the next step might be to consider submitting an Operational Safety Case (OSC) for a reduction of operational limits in congested areas. This might be considered to be a natural, logical progression but applicants should consider a few things before embarking on this path. In the first of a series of articles looking at Congested Area Operational Safety Cases (OSC), ClearSky Consulting focuses on some key questions to ask yourself first.
Do you need one in the first place?
This seems like an obvious question but it is one you should properly consider before you start the process of compiling an OSC. It might be that the amount of work opportunities available to you are increasing in congested areas but it is worth doing a full Cost Benefit Analysis (CBA) to establish the need. Compiling an OSC can be a timely (and therefore costly) activity and you need to be sure that the return on the investment will be established within an acceptable timeframe. The last thing you want to do is to submit and OSC for a promising initial urban survey project only to find that there is a limited pipeline beyond that. The big question then is, do your figures stack up in this respect?
What reductions do you require?
The outcome of an OSC is for the CAA to issue an amended PfCO with reduced operating limits from people not under your control (which may include overflight) and it is important for an applicant to understand the responsibility inherent in these reductions. You need to be confident that you can reduce your lateral limits to a distance that is manageable and proportionately safe, factoring in the breadth of your experience, knowledge and proficiency. If you think that you can simply reduce to 5 metres and be safe throughout all operations then you probably haven’t fully considered the safety factors that apply. This requires a good measure of knowledge about your own operation and this is often where operators fall down after they have achieved their initial PfCO.
Additionally, you will need to accept that the OSC submission will ultimately bring a reduction that can only be supported by the weight of your safety argument. So, if you want a reduction to 10m but only supply an argument that, in the view of the CAA review team, only warrants 30m, then you will need to accept what is issued. The path to addressing this and achieving what you think you can operate safely at lies in the next point.
Understanding the need to ‘own’ the safety case
Much like the Operations Manual principle, the OSC applicant must ‘own’ the submission and subsequent PfCO exemption. To do this, they must immerse themselves in compiling a coherent safety argument underpinned by a body of evidence, activity which is not directly revenue related. This is a difficult thing for a small SME that might be living a ‘hand-to-mouth’ existence in a competitive marketplace. An OSC brings a plethora of extra safety measures which must not only be outlined in the Volume 1, 2 and 3 document set (and associated annexes) but must be complied with at all times and this can only be achieved if the applicant understand fully the specific safety argument and the day-to-day responsibility this brings. Ultimately, as in all things in the UK commercial drone environment, the buck stops with the Accountable Manager so they need to accept and embrace that responsibility.
In summary, if you want to start the process off on the right foot, commit to immersing yourself in your operation, understanding its strengths and weaknesses and how it will adapt and achieve a greater level of safety than it currently operates.
In Part 2 we will look at how to start building the OSC by conducting self analysis on your operation to determine where the current gaps exist between where you are and where you need to be for a successful submission.
ClearSky Consulting have successfully advised numerous clients in OSC generation in the UK. If you would like to explore what they have to offer in this respect then email: [email protected]