UAVs and Universities
A Workshop Guide
Presented by
Prof David Burton
Road Map
• Introduction.
• Part One: UAVs and Aviation Law.
• Part Two: The Permit for Aerial Work – Do you Need One?
• Part Three: Safe UAV Operation – Ten Essential Elements.
• Part Four: Governance and Management of UAV Operations in a
University Environment.
Between the various parts there will be an opportunity for questions
and also a final Q&A session at the end.
Introduction
Drones are Taking-Off in Universities!
• UAVs are a young and
dynamic technology.
• Autonomous flying robots.
• Offer enormous potential
benefits in many areas of
research and teaching.
• The ability to bring sensors
into otherwise inaccessible
environments, or
uneconomic applications.
The Challenge
• But this new technology is
challenging us.
• The regulatory environment is
unfamiliar, and dynamic.
• There is a feeling that there are
potential hazards and risks, but what
are they and how can they be
mitigated?
• The fact is “drones” are here to stay!
The pressure to use this easily
available technology is growing.
The Challenge
A Little Demonstration!
Part One:
UAVs and Aviation Law
The Legislation.
The Civil Aviation Act
(2012)
The Primary Legislation
The Regulatory Body
The Air Navigation
Order
The Secondary Legislation
The Legislation.
• The ANO deals with ALL civilian aviation in the UK. It is important to
understand that includes UAVs!
• Unless there is an explicit exemption, the provisions of the ANO apply.
• The ANO is a very large document – some 700+ pages and over 600
individual articles!
• But some provisions of the order are particularly relevant.
Let’s take a quick look at those articles of
the ANO that are most relevant to UAVs…
The Guidance.
• The ANO is the law – but
some of it requires a lot of
interpretation.
• CAP722 is intended as a
guide to the interpretation
of the ANO for UAV
operators.
• NOTE: CAP 722 is NOT the
law – it is guidance. But it is
guidance written by the CAA
and as such represents a
benchmark of best practice.
CAP722 – Unmanned Aircraft
Systems Operations in UK
Airspace – Guidance
The Guidance.
• CAP 722 puts some
suggested numbers to
things.
• E.g. VLOS is proposed as
500m radially and up to a
height of 400ft.
• But numbers like this need
to be carefully assessed.
• There is no doubt though
that operating with a firm
eye on CAP722 is good
practice.
CAP722 – Unmanned Aircraft
Systems Operations in UK
Airspace – Guidance
Legislation and Guidance.
Note that both:
The Air Navigation Order
(CAP 393) and
The Guidance (CAP 722)
are available to download free
from the CAA website.
Legislation and Guidance.
Some background reading for
you in the “useful links”
section.
A Police Guide to UAV
Law
The AAIB Bulletin.
The Legislation – A summary.
• EVERY flight carried out in the UK – whoever carries it out, for
whatever reason – must comply with the ANO. Yes even the kid flying
a toy plane in the park!
• Anyone operating a UAV on behalf of a university should:
• Be thoroughly familiar with the relevant provisions of the ANO.
• Have an intimate, thorough and detailed knowledge of CAP722.
• Failure to do this could be considered irresponsible from a safety
point of view and leaves you open to prosecution by the CAA, or the
police and possibly civil liability for damages.
UAVs and Aviation Law.
Part Two:
The Permit for Aerial Work
The Permit for Aerial Work.
Article 166 para 5 of the ANO states:
“The person in charge of a small unmanned aircraft must
not fly the aircraft for the purposes of aerial work except in
accordance with a permission granted by the CAA.”
The CAA defines Aerial Work as:
“…any purpose (other than public transport) for which an
aircraft is flown if valuable consideration is given or
promised in respect of the purpose of the flight...”
The Permit for Aerial Work.
The key question:
“Is what we do with UAVs in Universities Aerial Work as
defined by the CAA?”
The Permit for Aerial Work.
At this point a thought may
cross your mind:
“Why don’t we simply ask
the CAA? We could get a
definitive ruling then we
would all know exactly
where we stand!”
The Permit for Aerial Work.
• The simple fact is that the CAA
either won’t or, more likely,
can’t answer this question!
• Each institution must find their
own answer. And it has to be
an institutional answer – not a
“team by team” answer.
Aerial Work?
• To find the answer for your institution the point you need to consider
is:
• Is there anything which a reasonable person might consider to be
“valuable consideration” for the pilot, the institution or any
collaborator, associated with the purpose of any flight someone
may undertake on behalf of the university?
• This is more difficult to answer than you might think! Let’s take a look
at a few possible scenarios,….
Aerial Work – Scenario 1
• The curious academic.
academic.
• No grant
• No project
• No specific aim
• So maybe this isn’t for
valuable consideration?
• But who is paying him, who
owns the UAV and what
exactly is his job?
• What happens when he
publishes/applies for a grant?
• The problem of lack of
regulation/monitoring.
Aerial Work – Scenario 2
• The “hot shot” academic.
• Big grant income to the university,
contract specifies deliverables
produced via UAVs.
• Industrial partners looking to
commercialise.
• It is his job and he’s paid for it.
• Big external profile
• This looks awfully like “valuable
consideration” to me!
Aerial Work – Scenario 3
• The teaching academic.
• Builds the use of UAVs into their
teaching.
• Starts an MSc programme.
• Lots of students paying fees
learning how to use UAVs and doing
project work.
• This could certainly be seen as for
“valuable consideration”.
Aerial Work – Scenario 4
• The enterprising academic.
• Does lots of work with companies.
• Using UAVs.
• Straight commercial proposition as
a consultancy.
• This is without doubt for
“valuable consideration”.
Aerial Work – A Spectrum?
A nice neat model – but sadly not a very accurate one!
Aerial Work – A Multi-Ring Circus.
The Permit for Aerial Work.
• So the key question is: Is anything, that even one of these
hypothetical academics are likely to want to do with drones,
for “valuable consideration”?
• The answer has be an institutional answer – because the
Permit is issued to a “legal body” – in most cases that will be
the university.
• If one thing you are doing needs a Permit, then the
institution needs a Permit!
The Permit for Aerial Work – Pros & Cons
• What are the arguments against getting a Permit?
• It is a lot of work!
• You will need to develop and have adopted an institution wide
procedure for the use of UAVs.
• You will need some form of “governance and management
structure”.
• You will have to think carefully about exactly what you intend to
do with UAVs.
• It will cost you money – directly and indirectly.
• Users may resist! They may see it as a burden and “overly
bureaucratic”.
The Permit for Aerial Work – Pros & Cons
• What are the arguments for getting a Permit?
• It completely removes doubt and the need to access each and every
mission as to whether it is for valuable consideration or not.
• It requires you develop safe working practices and to document them.
• It requires you to train people so they are safe, skilful, operators.
• It requires you to maintain proper records.
• It considerably expands your operational capability.
• Many of your collaborators will require you to have it. (Awareness on
point this is increasing rapidly with large companies, public authorities
etc.)
• It protects the institution.
Getting it Wrong
The Potential Consequences
The Consequences of Getting it Wrong.
What might the consequences be if we call this the wrong way?
First of all let’s look at what might happen if you decided that you
didn’t need a Permit, but the CAA subsequently ruled that what you
doing was for “valuable consideration”.
The Consequences of Getting it Wrong.
• The consequences:
• The CAA would prosecute you for a breach of clause 166 of the ANO.
• You would be fined – a few thousand pounds.
• You may have your UAV equipment confiscated.
• Relatively “small beer”, right? But….
• The reputational damage is not good!
• The institution looks amateurish and as if it has a cavalier attitude to
legislation and safety.
But this is if you are lucky. It could be much, much worse.
Let’s look into the Abyss!
The Consequences of Getting it Wrong.
• The Nightmare Scenario:
• You have no permit and no systems
or central procedures.
• Your “hot shot academic” is flying
his 25lb UAV with 5lbs of payload
data gathering equipment on
board. Total take off mass 30lb
• In flight a critical solder joint in the
propulsion power train fails.
• The aircraft falls like a stone.
• It lands on someone who, as result,
suffers fatal injuries.
• What’s going to happen now?
The Consequences of Getting it Wrong.
• The Nightmare Scenario – what’s going to happen now?
• For starters the CAA are still going to prosecute you under article 166
of the ANO for undertaking aerial work without a permit.
• But the fine will be higher because the UAV exceeded the 7Kg
threshold. (The threshold the operator didn’t know about!)
• This decision is important because it establishes that the flight itself
was illegal and this will have major knock-on consequences.
The Consequences of Getting it Wrong.
• The Nightmare Scenario – what’s going to happen now?
• As a consequence of the death, the police (and most probably the
AAIB and the HSE) are going to commence investigations. What will
they find?
•
•
•
•
•
•
•
•
You have no maintenance logs or formal procedures for the aircraft.
There are no formal, documented and adopted, pre-flight check procedures.
The operators of the aircraft had received no formal training.
The pilot of the aircraft had no specific qualification for the task.
The was no formal mission planning document.
The is no formal mission approval process.
There was no risk assessment carried out.
There are no formally laid down emergency procedures.
The Consequences of Getting it Wrong.
• The Nightmare Scenario – what’s going to happen now?
• Things are not looking good. The men in suits are using words like
“negligent” and “reckless”.
• Just when you thought it couldn’t get any worse,… the family of the
victim start a legal action for damages and compensation. This could
run into millions.
The Consequences of Getting it Wrong.
• The Nightmare Scenario – what’s going to happen now?
• But you’re insured, right?
• But are you?
• Remember the CAA have established in court that you were engaged in an
illegal act! You cannot insure yourself against the consequences of an illegal
act.
• Check your insurance policy – it is likely that the cover is not in place unless
the pilot is an employee, is qualified and the flight fully complied with the
regulations of the CAA.
Should we apply for a Permit?
• The Nightmare Scenario.
• How likely is this scenario?
• In my personal estimation there are
1-2 deaths per year caused by radio
controlled aircraft.
• The largest UK insurance claim so
far was £4.5M
• Its hard to see why these incidents
should not increase with increased
usage.
• Robust safety procedures, allied to
good training, are our best defence.
The Consequences of Getting it Wrong.
• Turning to the positive side. If you hold a Permit you have significant
strengths in this unfortunate situation:
• You’ve removed the risk that the act of carrying out the flight in the first place may
have been illegal, so the consequences of its illegality go away.
• The process of applying for the Permit will have made you reflect and develop the
necessary procedures that promote effective planning and safe operations.
• Operating under the terms of a Permit will ensure that your staff have been properly
trained and, where appropriate, qualified.
• All of this will not only significantly lower the likelihood of accidents, it will
ensure that, should the worst happen, you can demonstrate that you had
good cause to be “reasonably satisfied that the flight could be completed
safely”. (ANO clause 166)
If You Do Want a Permit…
How do you get one?
How you get a Permit.
• All your pilots must hold a CAA approved qualification – as defined in
CAA publication IN2015-008.
• You must develop an institutional “UAV Operations Manual” which
describes in detail all aspects of your operation, management,
maintenance, training, procedures, emergency handling etc. etc.
• Submit these, together with details of your UAVs and form SRG1320,
plus payment, to CAA.
• And wait…. Takes approximately 30 working days – sometimes longer!
How you get a Permit - Training
• There are a number of NQE’s (CAA approved commercial training
organisations) that will do your pilot training and also support you in
developing your Operations Manual.
• Currently the CAA list 12 full NQE’s and two restricted NQE’s. A list
can be found at:
https://www.caa.co.uk/Commercial-Industry/Aircraft/Unmanned-aircraft/Unmanned-Aircraft/
The Permit for Aerial work – A summary.
• Whether you need a Permit or not is a decision YOU must make.
• In universities the situation is very complex – but if just one UAV
activity needs a Permit – then a Permit is required and remember, it is
institutional and then applies to everything you do with UAVs.
• It may not be necessary in some cases. But there many advantages to
having a Permit in terms of: procedures, operational scope,
governance, safety and institutional risk exposure.
• If you get this decision wrong – in the sense of not having a permit
but later being shown to have needed one - the consequences could
be severe, with prosecution by the CAA the least of your worries!
The Permit for Aerial Work
Part Three:
Safe UAV Operations
Ten Essential Elements
Safe UAV Operation.
• This is probably the greatest single
factor contributing to safe operation.
• Your pilots should be formally
trained to CAA approved standards –
anything else could be viewed as
irresponsible.
• Pilots practicing for tests should
always be accompanied by a
qualified pilot.
• Observers can be trained in-house,
but the there must be training and it
should be documented.
1. Training
Safe UAV Operation
2. Planning
• All missions, even training missions,
should be rigorously planned.
• Plans should be subject to an
approval mechanism.
• The plan should include all the
relevant information needed to have
“reason to believe the flight can be
completed safely” (ANO art 166).
• Plans and subsequent mission
reports should be retained
afterwards.
Safe UAV Operation
2. Planning
• Example content of a rigorous mission plan.
• Objective – flight plans, duration, secure take-off zones, alternate landing
zones.
• Personnel – who will be the PIC, how many observers and where?
• Equipment – what UAV, batteries, payload.
• Local Hazards – full site survey, with maps showing all ground and aerial
hazards, airspace classification, relevant NOTAMS, points of entry, features
under control, areas of limited visibility, restricted areas, “no-fly” zones.
• Risk Assessment – generic and site specific, also specific emergency plans.
• Contacts – local police, fire brigade, nearest hospital with a minor injuries
clinic, nearest A&E, local ATC if needed.
• Environment – weather forecasts (updated), GPS factors (number of
satellites, Kp etc.)
• Data Plans – including privacy, data protection, archiving, curating, intended
uses etc.
Safe UAV Operation
2. Planning
• How comprehensive (large!) should a mission plan be?
• As big as it needs to be to answer the question: “do you have good reason to
believe this flight, or these flights, can be completed safely”.
• You can use ‘pro-forma’ mission plans for familiar sites.
• Mission plans should be kept for several reasons:
• They are record of what happened.
• They are your collective “memory”, your experience bank.
• They establish your experience and safety record.
• If you get into the habit then doing mission plans it becomes the
norm and is no “big deal”.
• No one should think that it is acceptable to take a UAV to a place
they are not familiar with and just fly it. That way leads to surprises
– and in the aviation world we don’t like surprises!
Safe UAV Operation.
• You should have a specific UAV
incident reporting procedure.
• An “incident” is anything that
happens that was outside of the
mission plan.
• Aviation incident reporting and the
“no blame” culture.
• The objective is to learn and improve.
• Flight crew should feel safe that if they
are following procedure they will not
be blamed.
3. Incident Reporting
Safe UAV Operation
4. Record Keeping
• You should have a robust system of
record keeping.
• Items you need to record:
•
•
•
•
Pilot logs
UAV logs
Maintenance logs
Battery Logs
• You might find this easier via a
facility like Sharepoint or some other
web accessible database.
• Management should have overview.
Safe UAV Operation.
• The atmosphere around UAV
operations is often very distracting
and pressurised. Operators should
not rely on memory for correct
procedures.
• Checklists needed:
•
•
•
•
Maintenance checks
Pre-deployment
Pre-flight
Post-flight
• Ensure that checklists are actually
used!
5. Checklists
Safe UAV Operation
6. No Solo Operations
• Operating UAVs alone should be
explicitly prohibited.
• Three reasons:
• It is unsafe for the person concerned.
• There should always be at least one
“spotter” or observer. The pilot cannot
do this adequately.
• Correct use of checklists requires at
least two people.
• The second person does not have to
be a qualified pilot, but they should
have received observer training and
they should be fully briefed by the
pilot on the mission.
Safe UAV Operation.
• Implement the concept of the PIC
(Pilot in Command)
• One single person with the
responsibility for the safe and
successful delivery of the mission.
• Other flight crew members –
observers, payload masters etc. –
are under the PIC’s command for the
duration of the mission (regardless
of rank!)
• Back your PIC’s up – sometimes they
have to make unpopular decisions!
7. Clear Command
Safe UAV Operation
8. Failsafes
• You should have an agreed failsafe
policy. It should cover loss of control
signal with and without GPS.
• Failsafes should be active on every
flight in accordance with the policy
agreed.
• Failsafes should be checked regularly
and the checks logged.
• Failsafes should be “spot inspected”.
Safe UAV Operation.
• New systems must be tested, under
controlled conditions, before
deployment in-mission.
• No new system or facility should be
tested in a mission scenario.
• The execution of the test and the
result should be recorded in the
UAVs maintenance log.
8. Testing
Safe UAV Operation
9. Health Checks
• You should implement a basic health
check procedure for all flight crew –
but specifically for pilots.
• This does not have to be a medical
examination. Questionnaire with a
possible follow up is fine.
• It should ensure basic fitness for
duty.
• Alcohol and drugs policy.
• Careful of Equal Opportunities and
the DDA here!
Safe UAV Operation.
• Some types of emergency are
generic – non site specific.
• Have a formal written down generic
emergency procedure.
• Make sure all operators know it and
follow it.
• Typical examples:
•
•
•
•
•
Fire
Accident
Fly away
Pilot incapacitation.
Etc.
10. Emergencies
Safe UAV Operation. A Summary.
• There are many other things that could be added.
• One of the major benefits of applying for a CAA Permit for
Aerial Work is that writing an institutional Operations
Manual is a catalyst to thinking more deeply and in a more
structured manner about safety and UAVs.
• Even if you are not applying for a Permit it is worth
seriously thinking about developing an Operations Manual
that defines how your Institution will safely operate UAVs.
Safe UAV Operation.
Part Four:
The Management and
Governance of UAV Operations
in Academia.
Management.
• What are looking for in a UAV management and
governance system?
• Promotes and attempts to ensure, as far as possible, safe operation.
• Keeps the institution safe by ensuring full compliance with all legal and
regulatory requirements.
• Provides a system for the creation and maintenance of proper records.
• Oversees training.
Management.
UAV Operations
Manager
A key person!
Management.
• The role of the Operations Manager:
• Overseeing training, ensures that all pilots are qualified and current. Also
that training is provided for observers and payload managers where
appropriate.
• Acts as a point of advice for all users – particularly new or aspiring
operators.
• Mission Plan approval and allocates resources to Missions – human and
equipment.
• Checks record keeping is taking place.
• Maintains the currency of the Operations Manual.
• Liaises with CAA and other external agencies on behalf of the university, in
particular maintains the currency of the Permit (if in place).
• Organises any necessary incident investigations.
• Acts to ensure, as far as practicable, that flight crew are fit for duty.
Management.
UAV Operations
Manager
Deputy
Operations
Manager
Deputy
Operations
Manager
Faculty or
Research Group
Faculty or
Research Group
Deputy
Operations
Manager
Faculty or
Research Group
Management.
Commissioner/Client
Proposed Mission Plan
No
Approval
Yes
Approved Mission Plan
Mission Report
Mission Delivery
Management.
• Record checking can be made significantly simpler for users and
management via the use of web-base systems.
• For example, Sharepoint folders can be set up for:
•
•
•
•
Individual pilot logs
Individual UAV maintenance records
Battery logs
Mission Plans and Mission Reports
• These are accessible by all users – even in the field with a 4G
device.
• Also available to Operations Managers for inspection.
• Means records can be retreived quickly, anywhere.
ARGUS.
• Just before we finish with a general question and answer session:
ARGUS
Aerial Robotics Group of Universities and
Scientists
Open Session!