GM1 Article 16(1) UAS Operations in the Framework of Model Aircraft Clubs and Associations
CAA ORS9 Decision No. 46
APPLICATION GUIDANCE
An application for an Article 16 authorisation will need to include a risk assessment. This should include the following (this list is not exhaustive):
- Description of the Association and its membership, including current total number of members;
- Description of flying activity, including locations and type of flying carried out;
- Description of competence and achievement schemes;
- Organisational structure, including organogram;
- Relevant procedures and processes within the association- including occurrence reporting and membership oversight;
- Description of which parts of the regulatory framework the association wishes to be excluded from. This should be included in a suitable tabular format, for example:
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Article of Regulation |
Requirement |
Requested change |
Reason |
Supporting Evidence |
|---|---|---|---|---|
|
Article 4 (1)(e) |
During flight, the UA is maintained within 120m from the closest point on the surface of the Earth. |
During flight, the UA is maintained within 450m from the closest point on the surface of the Earth, for model aircraft with a mass less than 7.5kg. |
Requirement to regularly fly above 120m for flight training and displays. |
Risk assessment Volume 3 |
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- A safety case to provide evidence supporting the application. This should support any requests made in the table above.
Before submitting the application, the association should engage with the CAA RPAS and GA Unit to establish whether the Article 16 Authorisation is likely to be granted, and to answer any initial queries. Some basic feedback may be given at this stage, but a full review and feedback will not be given until the application is submitted.
Following submission of the application, an initial meeting will be arranged to discuss the application with the association, and once issued, regular meetings will be held with the association.
NOTIFICATION OF MODEL AIRCRAFT ACTIVITY TO OTHER AIRSPACE USERS
Consideration should be given to the need to notify other airspace users of model aircraft activity, when operating within the terms of an Article 16 authorisation. This should be identified at the time of application, during the risk assessment process.
Generally, this includes when operating above 400ft AGL as part of a display, or when operating a large model aircraft above 400ft.
Model aircraft operating within an aerodrome FRZ may be notified to other airspace users, via a NOTAM. This is at the discretion of the aerodrome ATS unit, and the recommendations set out in AIP section ENR 1.1 – 4.1.8.13.
Generally, a VLOS operation of a model aircraft does not require notification when above 400ft, when stated within the terms of the Article 16 authorisation and when outside controlled airspace.
The primary means of notification is via a NOTAM. A NOTAM highlights important operational information to pilots, which is checked as part of the brief before departure. NOTAMs are issued by the NOTAM office at NATS, and can be arranged by the CAA, individual operators, aerodromes or other agencies as necessary.
A NOTAM should be used to highlight unusual model aircraft activity to other pilots for awareness. This includes displays above 400ft, large model aircraft operating above 400ft and in some cases, when operating within an aerodrome FRZ. A NOTAM may be requested via the online form, available from the CAA website here , or for an aerodrome ATZ, by the aerodrome contacting the NOTAM office.
In general, a NOTAM should not be raised for an activity which is also notified within the AIP (section 5.5 (aerial sporting and recreational activities). However, it is acknowledged that some sites in some instances (large display events for example) may need additional notification, in order to improve their visibility to airspace users, particularly the VFR GA community. In this case, a NOTAM in addition to the AIP entry may be requested for ‘an intense area of model aircraft activity’. These should be requested when necessary via the online form, available here.
NOTIFICATION OF MODEL AIRCRAFT ACTIVITY TO THE ANSP
Model aircraft operations within controlled airspace, above 400ft, are expected to be considered within the Article 16 risk assessment. Compliance with procedures set out within the AIP is expected, and may form part of the air risk mitigations.
In this case, when a model aircraft operates above 400ft within controlled airspace, the UAS Operator should identify whether the portion of airspace requires a notification to the ATS unit responsible. This will be set out within the AIP, section ENR 2.1. This process is set out in GM1 UAS.SPEC.040(1)(b), and should be followed.
MILITARY LOW FLYING SYSTEM
The military operate a system of low flying routes throughout the UK, and frequently fly below 500ft, often to heights as low as 100ft. The vast majority of military low flying takes place between 250ft and 500ft, and usually on weekdays between 0700-2300 (GMT).
In order to assist deconfliction between low flying military aircraft and other civil airspace users, the low-level Civil Aircraft Notification Procedure (CANP) has been established to provide a means of notification to the low flying cell.
Model aircraft displays and any other intense model aircraft activity should be notified through the CANP process, by emailing the low flying booking cell. Contact details for the cell are published in the AIP, in section ENR 1.10 - 5.1.
Charts of the low flying system are available from the AIP (ENR 6-20 and 6-21), which show the tactical training areas, boundaries and areas of avoidance.